This comment letter response contains two parts:   

(1) The original submittal from the commenter.

(2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the

original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA‐assigned comment code; and an

individual response. These are described and explained below.  

• The data base contains Comment text from the letters submitted by commenters.  

Many hard copy letters were scanned into electronic format for inclusion in the data

base. As a result, there may be some typographical errors attributable to optical

character recognition issues.  However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and

appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique

Comment ID.  Additionally, one or more Comment Codes (i.e., unique topic area ID) was

assigned to each discrete point raised by a commenter. This information was added to

the data base. To inform final rulemaking decisions, all comments and information

received on a given topic were reviewed by technical experts in each rule area (e.g., on

construction requirements).  

• Following decisions on the final rule requirements, Individual responses were drafted

by topic area to ensure completeness and consistency of the responses with the final

rule and other responses to similar comments.  Each discrete point made by a

commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.

Each letter response is a compilation of each comment and its individual response,

compiled in the order of the original comment letter.  As a result of this process, there is

repetition in the response text.  The Agency believes this approach ensures completeness

and attention to each comment letter that was submitted.   

• All comments in a topic area were reviewed, evaluated, and responded to concurrently.  

Responses on each topic area are compiled and are also available in the rulemaking docket.
Environmental Protection Agency proposed Federal Requirements under the Underground

Injection Control Program for Carbon Dioxide Geologic Sequestration Wells. 

Proposed Regulations Published in the July 25, 2008 

Federal Register Notice 

Docket #: EPA-HQ-OW-2008-0390 

October 13, 2009 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, NM 

Washington D.C. 20460 

Docket, 

The Fond du Lac Band of Lake Superior Chippewa (the “Band”), a federally recognized tribe, 

appreciates the opportunity to respond to the proposed Federal Requirements Under the 

Underground Injection Control (UIC) Program for Carbon Dioxide (CO2) Geologic Sequestration 

(GS) Wells. 

The Fond du Lac Reservation and the related Ceded Territories are located in northeastern 

Minnesota, a region with significant metal extraction activities, associated fossil fuel electric 

generating units, forest product industry, with land and sea shipping hubs. The region is home to 

the Ojibwe people and the tribes retain usufructuary rights (hunting and gathering) in the Ceded 

Territories. The area has significant natural and freshwater resources including Lake Superior. 

As an indigenous population, it is of primary importance to work to toward maintaining and 

restoring the health of the environment as a direct means to improve the health and welfare of the 

Band. As a community, we must protect and heal Omizakamigokwe, Mother Earth, the provider 

and live sustainably within the environment. 

General 

The proposed rule is quite specific and seeks to compartmentalize comments only to the 

endangerment that may be caused to underground sources of drinking water (USDW). However, 
the proposal goes on to state that the Class VI injection wells are to be one approach “that could 

be deployed to reduce CO2 emissions to the atmosphere and help to mitigate climate change.” 

While such specificity allows for a focused approach, if approved, it may allow Class II wells to be 

used for GS of CO2 under the rule. The use of Class II wells for GS of CO2 will likely allow carbon 

credits in one form or another, even though the injected CO2 would be used to enhance the 

extraction of additional fossil fuels (oil or natural gas), which when consumed releases CO2, 

impeding rather than mitigating CO2 emissions. 

If the proposed wells are to be a part of a climate mitigation strategy, supporting data must be 

supplied to verify that goal. 

Assessment of the Proposed Rule

The proposed rule repeatedly references climate change mitigation by the injection of CO2 as the 

justification for the need for the new class of injection well: 

Summary: 

“EPA is proposing Federal requirements under the Safe Drinking Water Act 

(SDWA) for underground injection of carbon dioxide (CO2) for the purpose of 

geologic sequestration (GS). GS is one of a portfolio of options that could be 

deployed to reduce CO2 emissions to the atmosphere and help to mitigate climate 

change.” 

And 

“If finalized, this proposal would help ensure consistency in permitting underground 

injection of CO2 at GS operations across the U.S. and provide requirements to 

prevent endangerment of USDWs in anticipation of the eventual use of GS to 

reduce CO2 emissions.” 

In Part II “What is the EPA Proposing” the proposition reiterates: 

“In addition to protecting USDWs, today’s proposed rule provides a regulatory 

framework to promote consistent approaches to permitting GS projects across the 

U.S. and supports the development of a key climate change mitigation technology.” 

Under Part II A. “Why Is EPA Proposing To Develop New Regulations To Address GS of 

CO2?” Part II. Section 2, states: 

The Intergovernmental Panel on Climate Change (IPCC) has concluded that much 

of the warming in recent decades is very likely the result of human activities (IPCC, 

2007). The burning of fossil fuels (e.g., from coalfired electric plants and other 

sources in the electricity and industrial sectors) is a major contributor to humaninduced greenhouse gas emissions. 

Fossil fuels are expected to remain the mainstay of energy production well into the 

21st century, and increased concentrations of CO2 are expected unless energy 

producers reduce the CO2 emissions to the atmosphere. The capture and storage 

of CO2 would enable the continued use of coal in a manner that greatly reduces 

the associated CO2 emissions while other safe and affordable alternative energy 

sources are developed in the coming decades. Given the United States’ abundant 

coal resources and reliance on coal for power generation, CCS could be a key 

mitigation technology for achieving domestic emissions reductions” 

And: 

“Congressional climate change legislative proposals (the McCain-Lieberman bill S. 

280, the Bingaman-Specter bill S. 1766, and the Lieberman-Warner bill S. 2191) 

indicate that CCS has the potential to play a significant role in climate change 

mitigation scenarios.” 

And: 

“Today’s proposal provides a regulatory framework to protect USDWs as this key 

climate mitigation technology is developed and deployed.” 
The allusion of mitigating climate change or reducing CO2 emissions by geologic sequestration 

cannot be fairly used as persuasive point for this rule without providing data demonstrating the 

mass balance of energy and carbon dioxide in the whole system. 

A great deal of analysis has been completed and posted on the docket of cost and incremental 

cost within the proposed rule for CCS and GS implementation but no analysis is made in terms of 

the actual amount carbon dioxide that will be sequestered in relation to the amount of carbon 

dioxide emitted throughout the process (Cost: EPA–HQ–OW–2008–0390-0073 and EPA–HQ–

OW–2008–0390-0094). 

A mass balance of the participating fossil energy processes, generating the CO2, must be 

evaluated to determine if any real reduction in CO2 can be made. CO2 is emitted during the 

excavation and transport of the fossil fuel to a power plant. Additional power will be required, and 

will emit additional CO2, to provide the energy to extract the CO2 from the emission stream, to 

compress, transport, and to inject the CO2 into a geologic formation. 

Very little data is available to evaluate the energy balance of various carbon capture processes. 

The evaluations available limit the efficiency of carbon capture (CC) to a percent recovered from 

the feed stack to the emission stack. Capturing the carbon is very energy intensive and may 

increase energy demand by up to 50%. (www.lowtechmagazine.com accessed October 27 2008). 

According to Greenpeace International: False Hope: Why carbon capture and storage won't save 

the climate, “capturing and storing carbon uses lots of energy; anywhere from 10-40% of a power 

station’s capacity. An energy penalty of just 20% would require the construction of an extra power 

station for every four built. These reductions in efficiency will require more coal to be mined, 

transported, and burned, for a power station to produce the same amount of energy as it did 

without CCS.” 

The attached summary of a study by Wuppertal Institute, the German Aerospace Center (DLR), 

Zentrum für Sonnenenergie- und Wasserstoff-Forschung Baden-Württemberg (ZSW) and the 

Potsdam Institute for Climate Impact Research (PIK) for the German government (the full report 

available at: www.wupperinst.org, accessed on line Dec. 23 2008) offers an in depth study of 

CCS that evaluates the various power plant designs, transport, and storage costs; accesses life 

cycle, ecological criteria, carbon neutrality etc. Estimates in the study show a 20 to 40% increase 

in energy consumption and the process will only lower emissions of CO2, ignoring the increases 

of other greenhouse gases (GHG). 

Consuming an additional 20 to 50% more coal to energize the capture of CO2 is a questionable 

tactic that must supported by transparent data analysis. 

Even as this proposed rule is being considered, the EPA is soliciting “applications to conduct 

research to support the development of sound risk management strategies for the underground 

injection of anthropogenic carbon dioxide (CO2)” (accessed online October 6 2008 

http://es.epa.gov/ncer/rfa/2008/2008_star_gsc02.html). The technology for GS of CO2 is not yet 

available or known to be safe. 

Social Justice: 

The United Nations Environmental Progamme states: 

“Globally around $300 billion or 0.7 per cent of global GDP is being spent on energy 

subsidies annually. 

The lion's share is being used to artificially lower or reduce the real price of fuels like 

oil, coal and gas or electricity generated from such fossil fuels. 

Cancelling these subsidies might reduce greenhouse gas emissions by as much as six 

per cent a year while contributing 0.1 per cent to global GDP.” 

Mr. Steiner added: 

"Whereas fossil fuel subsidies are an example of a blunt policy instrument, 

perpetuating old and inefficient economic models, the CDM is an example of a more 
intelligent, market-based mechanism that is fostering the transition to a modern Green 

Economy". (Accessed online Nov. 14, 2008 

http://www.unep.org/Documents.Multilingual/Default.asp?DocumentID=543&ArticleID=5902 )

Recommendations: 

• A thorough mass balance of the CO2 generated in the participating fossil energy 

processes, generating CO2 must be demonstrated to prove the feasibility of the proposal; 

including mining and transport of the fossil fuel to power plants, extraction and 

compression of the CO2 emissions, transport, and injection the CO2 into a geologic 

formation. 

• If carbon credits are developed, they must not apply to other UIC wells except specific 

Class V experimental wells. To use sequestered carbon dioxide under the auspices of 

this rule, to enhance the recovery of additional fossil fuels is imprudent and illogical. 

• Liability issues must be clarified in regard to human welfare and environmental protection 

rather than ensuring the financial viability of the commercial entities of power plants, 

pipeline, and well operators. Proponents wish to diminish liability for CCS and GS 

activities (EPA-HQ-OW-2008-0390-0150.1) and EPA must explicitly recognize the threat 

of an uncontrolled release of CO2 to human life. Acknowledgement of the potential 

hazard, in a manner similar to OSHA guidelines on “gases, vapors, fumes, dusts, and 

mists - 1926.55” would be beneficial. 

• Fond du Lac will defer to the experts in the case of pipeline and well integrity and the long 

term safety of geologic sequestration of carbon dioxide. However, the skill of deep drilling 

brings to mind the mudflow disaster of Sidoarjo Porong, East-Java Indonesia, which 

began in May 2006 and is still flowing to this day. 

• Financial Assurance should be required for any unforeseen effects of a given project. 

Conclusion: 

Although the effort made to address the serious issues of climate mitigation through CCS is 

greatly appreciated, the effort largely appears to mitigate CO2 emissions via a complex system 

that will, in reality, increase fossil energy consumption. With projected consumption to increase 

more than 30% by 2030 and CCS adding at least 20% additional demand, one may wonder if this 

proposal equates to yet another subsidy for fossil fuel industry. 

The absence of analysis of the carbon neutrality of this project is a serious omission. An analysis 

of this kind should have been the first step in evaluating this proposal, yet it is not addressed in 

the rule or in any of the supporting documentation. An endeavor of this magnitude should be 

demonstrably carbon neutral and hopefully operate as a true carbon sink. 

The commitment of resources; human, material, and capital, required to construct the network of 

pipelines and wells for a project that is most likely energetically untenable, cannot be supported 

without a proper evaluation of carbon throughput of the entire process. 

This rule is written for the existing energy production system. The reliance on fossil energy must 

change to meet the challenge of climate change. Barriers to the success of alternate sources of 

energy must be removed so the issue can be faced head on. This rule will impede and obstruct 

progress for those competing industries. 

The resources required to pursue this undertaking will be in direct competition with efforts 

focused on sustainable energy sources and alternative, arguably more effective carbon 

sequestration, utilizing wetland restoration, improved agricultural methods, and sustainable 

forestry practices that have numerous and vital fringe benefits. 

Experts in carbon sequestration know that utilizing biologic methods of carbon capture is cost 

effective and will include economic benefits. For example, wetland protection and restoration will 

not only sequester carbon but will purify water, impede drainage (flooding), and replenish 
aquifers. Many avenues could be used to reverse engineer the activities that drained these 

wetlands. Many studies including the Kyoto Protocol Wetland Restoration and Management and 

the Wilderness Society Forest Carbon Report support these alternative carbon sequestration 

mechanisms. 

Reduction of carbon emissions to the atmosphere is the primary driver for this new class of well, 

proof that carbon capture and sequestration will provide a net removal of CO2 must be provided 

else any reference to the reduction of CO2 emissions or climate mitigation must be removed from 

the document. 

Respectfully, 

Mary Munn 

Air Program Coordinator 

Fond du Lac Reservation 

1720 Big Lake Road 

Cloquet MN 55720 

 

marymunn@fdlrez.com 

Office: 218.878-8030 

c.c. Wayne Dupuis – FdL Environmental Program Manager 

 Dennis Peterson – FdLTribal Attorney 

 Darrel Harmon – EPA, HQ 

 Ben Giwojna – EPA, Region V 

 Laura McKelvey – EPA, OAQPS 

Stephen Hartsfield – NTAA 

(Previously submitted Dec 23 2008 to OW-GENERAL@epa.gov' and Dec 29 to docket Contact Lee 

Whitehurst) 
, Wuppertallnstitute 

« m for Climate, Environment 

and Energy 

PIK 

RECCS 

Ecological, Economic and Structural Comparison 

of Renewable Energy Technologies (RIE) 

with Carbon Capture and Storage (CCS) -

An Integrated Approach 

Research project 

fundedby ttl Federal Ministry for the 

Environment, Nature Conservation 

and Nuclear Safety 
IMPRINT 

Publisher: 

Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU) 

Content: 

Wuppertallnstitute for Climate, Environment and Energy (WI) 

Dr.~lng. Manfred Fischediek (co~ordjnatorl 

Dip!. Umweltwiss. A"ldrea Esken 

Soz,~Wiss, Andreas Pastowski 

Dipl.-Ing. Dietmar 5chOwer 

Dr. Nikolaus Supers berger 

German Aerospace Center (OLR) 

Institute of Technical Thermodynamics 

Dr, Joachim Nitsch 

Dr, PeterViebahn 

Centre for Solar Energy and Hydrogen Research (ZSW) 

Dr. Andreas Sandi 

Dr. Ulrich Zuberbuhler 

Potsdam Institute for Climate Impact Research (PIK) 

Dr, Ottmar Edenhofer 

Layout: VlsLab, Wuppertallnstitute 

Print: Offset Company, Wuppert,i 

Date: April 2008 

Download: www.bmu.de 

www,wupperinst,org/en/ccs 

Print run: 1,000 (long version), 1,500 (short version) 

Printed copies are available with the BMU (long version and short version) 

Contact: 

Dr.·lng, Manfred Fischedick 

Wuppertallnstitutefor Climate, Environment and Energy 

P. 0, 60x 10 04 80 

D,42004 Wuppertal 

Tel: +49,202,2492,121 

Fax: +49,202,2492,198 

E~ma ]1: manfred.fischedick@wupperinst.org 
Status Quo and the Aims of the Study 

Long-term scenarios on the development of energy 

systems show that the transition to a climate~frjendl)' 

energy supply will in Some way Tule out coaL However) 

coal is the fossil fuel with the largest globall'eserves ~ 

distributed over many regions of the world and is sub~ 

jeet to fewer geopolitical risks than oil and gas. 

This raises the question of how the use of coal could be 

made more c1imate w friendly. Alongside improvements 

in the efficiency of the various ways c:oal is used (primarily by increasing the conversion efficiency of power 

stations and expanding the use of combined heat and 

power) the technology option of carbon capture and 

slorage (CCS) could also make a contribution. Its intro~ 

duction could make it possible to produce 'low-C02' 

energy based on coal. 1he important fields in this context are electricity generation, and even more so the 

production of hydrogen as a W1iversal storable fueL 

The same a.lso applies in principle to natural gas and oill 

although from the dimate perspective natural gas is a 

less critical issue owing to its lower carbon intenSity. 

There are still many unanswered questions today concerning the possibilities of capturing CO2 and especially storing it safely (or a very long lime. These ques~ 

tions include not only how much safe, iong-term storage 

capacity there rKtually is for CO2 (and its regional distribution), but also what costs and ecological risks are 

involved.lfCCS can be succcssfuHy introduced as a new 

technology option at reas,onablc cost and with accept~ 

able ecological impacts, it could make a ma.jor contribution to providing a more secure and climate· friendly 

supply o( energy. 

Previous studies in this field have tended to concentrate 

on the general tech nita1 fe'Jsibilhy of the concept. There 

has not yet been a detailed examination of the eCQlogical, economic and social impacts along the whole 

process chain (e.g, energy balance, cumulative energy 

demand, environmental impact, use of resources, risks) 

costs) of the kind that is a matter of course today for 

other new technologies, especially renewables. Only 

after such scrutiny will it be pos~ible to decide how envi, 

ronmentally beneficial this teChnology option really is, 

what advantages and disadvantages it has compared 

with renewables and what contribution it can make to a 

sustainable economic structure. That is the focus of the 

present study. 

This project is particularly relevant in view of recenl 

political initlative~ on international level for using the 

so-called 'dean coal' option, extensive research activities 

globally and the publication of the German Environrnent Agency's assessment of CCS from the suslain w 

ability perspective in mid-2006, 

More and more scientists, politicians, and NGDs are 

calling for investigation and consideration of'dean coal' 

technology, 'Ihe energy sector itself is planning to open 

various small CCS demonstration plant in 2008 and the 

following years mainly in Europe and USA. 

The findings so far show that introducing carbon capture and storage only makes sense if done on a large 

scale. Given the great volume of investment required 

and the implications for other options for reducing 

greenhouse gases, the decisi<.m about whether CCS 

should be made a central pillar of energy policy will 

have to be thoroughly considered on a solid scientific 

basis. It is already recognised today that new tech nolo· 

gies will have to satisfy numerous technological, struc" 

tural, economk, ecological and social criteria before 

they can be regarded as viable options for a sustainable 

future energy supply. So they will be subjected to a rigw 

orous selection process before their suitability as future 

key technologies is accepted. As well as detailed investigation of the potential, the achievable future costs, the 

implications for industrial policy and social impact of a 

technology, difFerentiated life cycle assessments (LeAs) 

of the whole system represent a suitable instrument for 

assessing the practicability of new technologies agaimt 

various Sllstainability criteria. Very detailed LeAs are 

already available for the various technologies based 

on rel')ewables, which represent one of the main other 

options for avoiding greenhouse gases. Suitable data 

for making a solid assessment of capability and envi~ 

ronrnental and system impact are also already available 

for numerous technologies in the field of efficiency (e,g. 

modern combined heat and power). 

The goal of this project is consequently to weigh up 

the range of technologies for carbon capture and storage currently under discussion in terms of their fundamental suitability for a future energy supply. We outline 

several reference systems and realistic system configurations for supplying electricily and hydrogen together 

with all the relevant data required to properly appraise 

and assess the options in the scope of an overall con~ 

cept for a future sustainable energy supply. These make 

it possible to identify the fundamental potential of the 

proposed technologies, the technological advancements still required and the environmental impact. A 

systematic comparison with other options for a dirnatefriendly energy supply - especially the use of renewabies - concludes the stud}'. This if> the context in which 

the discussion about the possible role of the CCS option 
2 

in longer-Lerm energy supply scenarios must be conducted, in which the timeframe of future development 

steps (establishing an infrastructure) must be considered and in which fundamental energy policy decisions 

must be addressed. This investigation supplies a sophisticated set of data for placing the carbon capture and 

storage option in the energy and especially the climate 

poHcy context. As such it can make an important contribution to energy pOlicy decisions currently on the 

agenda. 

The principle research questions can be summarised as 

follows: 

• What are the conceivable routes for CCS (technologies, infrastructures, development timetables)? 

• What does the overall life cycle assessment of these 

processes look like, and how does low-C02 fossilbased electricity compare with CO2-free options, 

especially renewables (comparison on an equal 

footing)? 

• What role can CCS play for climate protection in 

comparison with other relevant options, and when 

(systematic comparison on the basis of significant 

criteria such as cost, timeframe, ecological restrictions, etc.)? 

• What role can CCS playas a possible bridge to a 

renewable energy system? 

The report has five parts: 

Part one (introduction and background) examines the 

driving forces behind CCS and the attitudes of relevant 

actors. 

Part two takes a closer look at technological developments in the field of CO2 capture (in electricity generation and hydrogen production) and at the individual 

steps involved in CO2 capture, transport and storage. 

The third part presents a comparative assessment of 

CCS and other relevant climate protection technologies 

on the basis of a comprehensive set of criteria. The life 

cycle assessment method (LeA) is used to conduct a 

thorough comparison of the ecological performance of 

CCS in comparison with continued expansion of renewabies. The economic parameters are also examined in 

greater depth. Additional criteria are used to differentiate and expand the comparison with renewables. 

Part four examines the significance of CCS for national 

energy sectors, including thorough system and scenario 

analyses. The significance of CCS and renewables for 

energy and climate policy are compared, The Germany 

energy system was chosen as an example. 

Status Quo and the Aims of the StudylL 

Finally, part five turns to a more global perspective on 

CCS, showing the requirements and preconditions that 

have to be met for international implementation of this 

technology option. 

Working GIOUp WI, OLR, ZSW, PIK 
Summary of Theses 

Driving Forces and the Attitude of Relevant Groups Towards (0, Capture and Storage 

• Climate protection is the most important reason for developing CO2 capture and storage. 

In particular sectors of the economy other economic incentives to capture CO2 already 

t:xist today (e.g. enhanced oil recovery). 

• Attitudes towards the technology are not uniform in different groups of society, CCS is 

often described as a possible bridge to the era of renewable energy. 

• Environmental organisations prioritise the further expansion of renewablcs and the full 

exploitation of energy-saving potentials. All environmental organisations reject the idea 

of storing CO2 in the oceans. Adequale proof of long-term stability is demanded for all 

storage options. 

(02 Capture Methods 

• Today there arc three technology options for CO2 capture in the short to medium term. 

Capturing CO2 from the flue gases of conventional power stations (post-combu.stion capture) leads to a significant increase in electricity generating costs, causes a comiderablc 

increase in fuel consumption and substantially reduces power station efficiency. Tn principle the technology is already available today, although it has yet to be demnnstrated at 

the scale of commercial power plant. 

• Capturing CO2 before combustion (pre-combustion capture) in coal~ or gas· fired power 

stations with integrated gasification (IGCC and natural gas combined cycle) is from 

today's perspective a more advantageous process than capluring CO2 from flue gas. 

Implementing this CO2 capture method would require considerable improvement and 

development, especially with regard to scaling it up to conventional power plant dimensions. 

till The oXjfuel process invoh'es burning fuel in pure oxygen and currently offers the best 

prospects for CO2 capture in terms of the achie\~able overall efficiency of the process and 

possibly also the resulting costs, because the components involved are largely based on 

conventional power station technology. A precise evaluation is not yet possible, because 

the process is only at the beginning of the demonstration phase. 

• Considerable additional costs must be factored in for capture at the power station, accord~ 

jng to current estimates between €35/t and €50/t CO2, Through research and demonstration projects and other technological improvements it is aimed to reduce the costs to less 

than €20/t CO" 

., As well as planning new builds with integrated CO2 capture it is in principle also possible 

to retrolil. BeGlUse of the strong increase in energy consumed internally, this only makes 

sense in power stations which start off with a sufficienlly high level of efficiency. In terms 

of technology, (Jue gati scrubbing is the primary option for retrofitting from today's perw 

spective. When power stations are planned today, the option of designing them to be 'capture ready' (prepared for retrofitting CO2 capture) should be considered. 

RECCS ProJl!ct 

3 
4 Summary of Theses 

Methods for (02 Transport 

• Energy efficiency. economic and ecological considerations mean that pipelines (onshore, 

possibly offshore loo) and large tanker ships are the only relevant transport options for 

large-scale implementation of CCS. 

• The decisive parameters for the source/sink relationship are in particular transport distance and capacity, but coordinating the timing of planning, approval and construction 

of power stations, pipelines and CO2 sinks is also relevant. The high investment costs 

involved in establishing a CO2 infrastructure necessitate forward-looking planning and 

coordination between the different parties involved. 

• Both gas conditioning (liquefying CO2 by compression, which reduces power station efficiency by up to 3.5 percentage points) and subsequent CO2 transport themselves require 

a more than negligible additional amount of energy, which in turn causes additional CO2 

emissions (and other greenhouse gases and pollution). 

• The range of cost estimates for CO2 is - depending on transport distance and capacity -

approx. €lIt to €10/t (for pipeline or ship transport) and represents about 10 % of the total 

costs of the CCS process (capture, compression, transport, storage). 

• In relation to the other infrastructure costs (electricity transmission, fuel logistics) the 

cost of CO2 transport is likely to be a secondary factor when selecting power station 

sites. Also, existing power station sites are often likely to be retained for reasons of public 

acceptance. 

• Transport of fuel (oil, oil products, coal) already represents a large proportion of total 

freight transport in industrialised countries. Introducing CCS on a large scale would considerably increase transport volumes - to supply additional coal and remove CO2 . There 

would also be a risk of pipeline or shipping accidents. although the risk per ship or kilometre of pipeline is relatively small. 

(02 Storage: Methods and Capacity 

• For various reasons the storage possibilities for CO2 are limited, both globally and nationally. Owing to the many uncertainties involved, current estimates of actual storage potential vary enormously. Global estimates show that although the potential is certainly considerable, in the long term it will certainly not be possible to solve the climate problem 

through CO2 storage alone. 

• Ecological, economic and capacity considerations mean that the only option e, g. for Germany is geological storage in empty gas fields and deep aqUifers. Taking into consideration only the country's major point sources and factoring in an average increase in energy 

use for CCS of 30 %. the static range in Germany is between thirty and sixty years. 

• Guaranteeing very low leakage rates is essential for the acceptance of underground storage. Corresponding evidence will have to be provided in a comprehensible form. 

• Little is yet known about the behaviour of CO2 in underground reservoirs. Research 

projects already under way should greatly improve knowledge of drilling and injection 

methods, distribution of gases in reservoirs and monitoring methods. 

Working Group WI. DLR. Z5W. PIK 
Summary ofTheses 

Comparative Ufe Cycle Assessments 

• From a holistic perspecti\'c the terms zero~carbon, zero~emissions and COr free are mis~ 

leading regarding fnssil fuelled electricity generation and hydrogen production. When 

the supply chain is taken into consideration and the usual assumptions are made about 

CO2 capture rates at the power station (88 % for post-combustion and pre~combusti()n) 

the potential for net CO2 reduction is found to be between 72 % and 78 %, If the full range 

of greenhouse gases is included, the reduction compared with a power station without 

CCS falls to a range of67 % to 78 %. Higher CO2 capture rates of up to 99.5 % (achievable 

with the oxyfuel process) allow in a coal-fired power station a net CO2 reduction of90 % 

and a net greenhouse gas reduction of78 %. 

o Tn this context it is more correct Lo speak of low-C02 or low~carboH electricity generation. 

The CO2 emissions from the 'best' fossil·fuelled power station from the climate protec~ 

tiol1 perspective (natural gas combined <:ycle, NGCC) are 'only' 50 % higher than those 

from the 'worst' CCS power station (coal·fired thermal power station with post~combustioo capture). 

.. The increased fuel consumption involved in CO2 capture and storage always leads to a 

proportional worsening of the outcome in the other impact categories. There are, however, exceptions: with post-combustion capture other emissions are reduced through reaction with the solvent acidification falls by 10 % and PMIO equivalents (particulate matter) increase by only about 2 %. On the other hand, eutrophication increases by 36 % and 

summer smog by 94 %, and demand for cooling water increases by up to SO % (post·com~ 

bustlon). 

o In comparison with CCS power stations, comparable large~scale renewable energy t>ys~ 

terns (e.g. solar thermal power stations, oft-shore wind farms) fare considerably better in 

aU impact categories across all stages of the process. Innovative fossil-fuelled power sta~ 

tion solutions like natural gas combined cycle (NGCC) including ht'at extraction and 

combined heat and power plant units (CHP) available today are comparably environmentally friendly as CCS plant are expected to be in 2020. 

Other Ecoiogkal Assessment Factors for ((5 

• As well as direct and indirect effects on the appearance of the landscape (e.g. caused by 

increased fuel consumption) and the negative consequences of increased transport volumes (of CO2 and additional fuel), the greatest other ecological impact would be the 

potential unplanned release of stored CO2 and the direct influence of the stored CO2 on 

the immediate vicinity of the sink over the course of time. 

• 'D1e different CO2 storage options differ from one another - sometimes conSiderably - in 

terms of ecological and safety considerations. Geological sinks (e.g. saline aquifers) are 

considered to have comparatively high long~term stability, but there is still great uncer~ 

tainty concerning the underground movement ofCOz and the resulting consequences. 

" Regarding CO2 storage in oceans its impact on marine ecosystems is still largely unresearched, but the expectable risks are so great that most countries rule out even conduct· 

ing further research into this storage option. 

Economic Comparison of «5 and Renewable Energy Technologies 

" In terms of electricity generation costs, a general structural difference must be noted 

when comparing CCS and rcnewables. Large or very large cost degression and learning 

effects arc still to be expected in both fields, but in the case of CCS these will be counter· 

acted by further rises in fuel prices. This effect is particularly strong in the case of gas· 

fired CCS power stations. 

RECCS PrOj('C1 

5 
6 Summary otrheses 

If) It can be assumed that electricity from renewable energies will become economically 

competitive Lo fossil~fuel based electricity earlier with the introduction ofCCS. By 2020 

- the earliest point at which CCS technologies are likely to be commerdally viable - a 

whole range of renewable energy technologies is likely to be able to supply electricity at 

cost conditions comparable to or better than fossil-fuelled power stations. In the longer 

term, renewables can be eX"'Pccted to have considerable cost advantages due to their independence from fuel price fluctuations. 

• The relative profitability ofeeS and renewables is currently still subject to many uncertainty factors. The aforementioned predictions for renewables afe based on assumptions 

of dynamic market development on a global scale, allowing very substantial cost dcgrcssion effects to be exploited through mass production and learning curve effects. 

• When it comes to hydrogen, production using renewables cannot be expected to become 

competitive with production using fossil fuels (including CCS) in the foreseeable future, 

'Whether or not this is the case, hydrogen is unlikely to become an important factor in 

the energy economy for several decades due to its generally high costs and the considera· 

ble infrastructure challenges associated with its introduction. But in principle this option 

represents an interesting strategic element for the transport sector - today still largely 

dependent on oil- and could potentially supplement biofuels as a diversifying element. 

The Role of ((S in Industrialised (ountries: the Example of the German 

Energy Supply System 

• The energy systems of industrialised countries are characterised by a number of shared 

features, Firstly. there is great potential for energy efficiency measures. on both the supply and demand sides. Secondly, the growth in energy consumption, and consequently in 

energy-related greenhouse gas emissions, is in general much slower than in developing 

countries. The special case for Germany is that it faces the complex challenge of having 

to replace a large proportion of its power station capacity within the coming fifteen years. 

The following theses are formulated for Germany, but are also applicable to other industrialised countries: 

• As the main element of a climate protection strategy (the CCSMAX scenario) CCS runs 

into structural and capacity limits, The earliest date when CCS technologies are expected 

to be ready for implementation is 2020, which is too late for the first wave of the necessary 

power station replacements, which has just begun. It would necessitate extremely rapid 

growth rales for CCS plant between 2020 and 2050 and speedy establishment of a hydrogen infrastructure. 

• If a vigorous political course of promoting renewables and efficiency improvements is 

pursued over the next ten to fifteen years, the realisation of energy-saving potential and 

the successive expansion of renewables would be able to make a more rapid contribution 

to climate protection than CCS. IncreaSing energy productivity makes sense in purely 

economic terms, too. Hoth strategy elements are also associated with strong innovative 

stimuli for taking a share of growing global markets. Considerable increases in effiCiency 

and the further expansion of l'cnewables are absolute preconditions for effective climate 

protection, If a sustained high tate of implementation is maintained, as described in the 

NaturschutzPlus (NATP) scenario) the use of CCS technologies is not absolutely necessary ttlf meeting even ambitious climate protection targets. The slrategy outlined in 

NATP is the best for the economy as a whole in the medium to long term, and should 

therefore be an aim of energy policy. 

Working Group IV', DLR, l1W, PIK 
Summary 01 Theses 

• The period until 2020 should be used to thoroughly explore the development and cost~ 

cutting potentials of CCS technologies and to demonstrate the technological feasibilIty. If that process proves successful, CCS would offer the possibility, as described in the 

BRIDGE scenario, of swib.:hing to a diO)ate~friendly path even jf it has not proved possible to sustain the ambitious pace of implementation of efficiency potentials and renewabIes over time. In view of the real intereslS involved in the field of energy, especially in 

the global context (where energy saving efforts are counteracted by substantial growth 

trends), this constellation may well become reality. 

• The successive introduclion of CCS after 2020 (presuming the availability of suitable 

sinks with long-term stability) tan act as an ancillary element helping to make it easier 

to maintain the ~ustaincd efforts that will be required to further improve efficiency and 

expand renewabJes. In this situation CCS can attain significant importance in fulfilling a 

bridging function to the establishment of a renewable energy economy. Consequently, it 

would appear that further development efforts for CCS are necessary and in the interna~ 

tiona I context of dirnate protection indeed unavoidable. But this must not occur at the 

expense of R&D efforts in the field of efficiency and renewables. 

.. Overall it must be ensured that measures for establishing a CCS infrastructure are compatible with the further expansion of renewables and that permanent structural ci)mmit~ 

ment.s and use conflicts (for example with geothermal energy or decentralised CHP) are 

avoided. 

• If CCS is included as a climate protection element, upcoming power station planning 

processes must already begin considering the possibility of future impicmentation of 

CCS. The idea of designing new builds 'capture ready' is central here, and is reinforced by 

discussions at the EU level about possibly making 'capture ready' status obligatory for all 

new power stations in the medium term. 

((5 in the International Context 

o Above all at lhe global level CCS could, from today's perspective, make a noticeable CO\1w 

tribution to meeting ambitious. climate protection goals alongside renewables and energy 

efficiency. Under plausible assumptions CCS could also help to reduce the economic costs 

of climate proteclion if today's e.xpectatiol1s about its technological development (espe· 

c1ally the cost-cutting possibilities) prove to be realistic. Including CCS in an integrated 

overall concept seems lo be one option to stabilise the CO2 concentration in the atmos+ 

phere at 450 ppm with an acceptable level ofloss of economic growth. This applies in particular if the alternative investment required in measures to adapt to the looming climate 

change is taken into account. 

• Internationally too, CCS can fulfil a 'bridging function' to an emission~free energy sys~ 

tern, but only if the technologies arc available in time for large-scale implementation and 

the costs of fossil fuels do not rise too steeply. 

• The largew::,cale introduction ofCCS presupposes that an institutional framework will be 

established (preferably at the international level) to sensibly regulate responsibility for the 

risks stemming from CCS (giving consideration to the rrecautionary and polluter pays 

principles) and offer involved parties an incentive to guarantee the safety of !:itorage. 

• Plausible proposals already exist for the shape of such an institutional framework (e,g. 

carbon sequestration bonds), that could be integrated in the existing climate protection regime and via market mechanIsms involve the public in decisions about the use of ccs~ 

RECCI Pro!", 

7 
8 SummaryafTheses 

• Further research - and also political decisions - are required conct'rning the development and discussion of the institutional framework, especially integration in the mechanisms of the UN Fra.mework Convention on Climate Change, the development of liability 

mechanisms and the implementation of legal provisions to restrict local risks associated 

with CCS. 

• In upcoming climate protection negotiations CCS could improve the chances of persuading more states (e.g, United States, China) to undertake firm obligations on emissions, 

because it would allow them to retain their familiar structures and their domestic primary energy base. 

• Ultimately, for reasons of capacity (limited storage potential and finite fossil energy 

resources), CCS cannot obviate the global need for further expansion of renewables and 

a considerable increase in energy efficiency. But under particular conditions CCS can 

help in meeting ambitious climate protection targets while at the same time extending the 

time available for the necessary restructuring of the energy system. 

Working Group WI, DLR, ZSw. PIK 
Summary 

Ba(kground and Introduction 

In recent years the discussion about carbon capture 

and storage (CCS) ha& moved steadily up the agenda 

in marty countries as well as globally in the context of 

meeting climate protection targets even more so as 

oil and gOiS prices have risen sharply and the increasingly urgent debate over security of energy supplies has 

swung towards greater LIse of coal. 

Carbon capture and storage technologies are not fundamentallf new. Some of them are already used on an 

industrial scale and fmds commercial application in 

oil extraction (enhanced oil recovery to increase the 

extraction rate of oil fields) or for conditioning natural gas (separating off the accompanying CO2), However, for the. much larger volumes that w01.lld gener~ 

ally be involved in application in power stations or for 

centralised hydrogen production numerous questions 

still remain unanswered. That also applies to the field 

of transport, to the pos5ible configurations of a CO2 

infrastructure and to storage. Demonstration projects 

(e.g. in Germany: 30 MWth pilot plant using the oxyfuel 

process, planned slart of operation 2008) and the first 

semi-commercial test facilities (the German company 

RWE Power AG plans to construct a coal-fired power 

!>tation with integrated gasification) CO2 capture and 

storage with a net output of360 MWd by 2014) aim to 

achieve significant progress in developing the technolo~ 

gies at the scale required for power stations. 

Studies so far conducted in this field have concentrated 

largely on the technical feasibility of carbon capture and 

storage. There has not yet been a detailed investigation 

of the ecological, economic and sodallmpact across all 

stages of the process (e.g, energy balance, cumulative 

energy demand, environmental impacl, resource con" 

sumption, risks and costs) of the kind that is today a 

matter of course for other new energy technologies, 

in particular renewable enery technologies. Only after 

such a study has been completed will it be possible to 

decide how environmentally benefidal the CCS option 

really is, what its benefits and drawbacks are compared 

to renewables and what contribution it can make to It 

sustainable economic structure, Including carbon Lap~ 

ture and storage in the fossil fuel cycle makes it possible 

for the first time to conduct a comparison with renew~ 

abies on equal terms (with re'pect to climate policy). 

Such a comparison, made on the basis of a comprehensive set of criteria, is the main objcct of the present 

study, answ~rillg the following questions: 

RECCS PrOject 

9 

• "'hat arc the conceivable paths fol' carbon capture 

and storage (technologies, infrastructures) and 

how do they fit on the lime axis (development perlods)? 

• How do the LCAs of these processcslook, and how 

does low~COz fossil electricity generation compare 

with CO2-free options (especially rencwables) in 

this respect? 

" What role can carbon capture and storage play for 

climate protection in comparison with other relevant options, and when (systematic comparison on 

the basis of significant criteria such as cost, window 

of opportunity, ecological rest riel l{)nS, etc.)? 

• What role can carbon capture and storage play at 

the national and international1cvels as a possible 

bridge to a renewable energy system? 

Driving For(es and the Attitudes of Relevant Groups 

towards Carbon Capture and Storage 

Several ditferent motivations are central to the development of technologies for capturing, transporting 

and storing CO2, Alongside climate protection as the 

overriding motivation, questions of security of supply, 

technological aspects, and in some cases also very real 

commercial considerations (e.g. measures in the field 

of enhanced oil recovery in countries with a CO2 tax 

such as Norway) playa decisive role. Technology that 

can generate progress in international dimate protection negotiations is of particular importance, Among 

the supporters of CCS are - above all ~ those states that 

have so far adopted a rejectionist or wait~and-see stance 

in the international climate protection process, such 

as the United States. "The United States has also made 

CCS a central priority of the Asian Pacific Partnership 

(APP), a more technology~oriented climate protection 

agreement that represents a counterpole to the Kyoto 

Protocol. 

Not least for these reasons, carbon capture and storage 

has become the subject of a broad range of networks at 

the international level, such as the Carbon Sequestra~ 

tion Leadership Forum (CSLF), which was initiated by 

the United States in 2003. 
10 

The attitudes of actors in society towards CCS differ rather widely. Across the 'i",orld environmental and 

nature conservation NGOs (non-governmental organisations) - with very few exceptions - agree on the fol~ 

lowing points and demands concerning CCS: 

• CO2 must not he stored in ecosystems (namely, 

oceans), 

• Long-term stability of storage systems must be 

demonstrably proven and guaranteed, 

lIP Development of CCS must not be at the expense of 

R&D funding for renewahles, and 

• Renewable energy sources and more rational usc 

of energy are preferable to CO2 storage, and their 

implementation should be stepped up. 

That is as far as the consensuS extends interna.tionally. 

German NGOs, for example, are generally at the more 

sceptical end of the international spectrum in their attitudes to CO2 storage. 

Political parties, too, differ in their positions on the 

technology. In Germany, for example, they range from 

the expectation that low·COz fossil·fuelled power stations will represent 'an important pillar' of energy pol· 

icy (the conservative CDU) to the call fOl' a coordinated 

research campaign (the social democratic SPD) or clear 

rejec:tion (the left-wing Die Linke). 

The positions of the different German ministries and 

expert committees can be summarised as follows: The 

Federal Ministry of Economics (BMWi) is supporting 

carbon capture and storage through the COORETEC 

research programme. This wide~ranging research pro~ 

gramme is designed to allow the proce&s of replacing 

and expanding capacity in the fossil~fuelled power sector that will begin around 2010 to be conducted at a 

high technological standard. The Federal Ministry for 

the Environrnc:lt, Nature Conservation and Nuclear 

Safety (BMU) and the Federal Environment Agency 

CUBA) believe that there are still many unanswered 

questions to be resolved before CCS can be regarded as 

a safe long· term option that is acceptable in social, e(:o· 

logical and economic terms. In a comprehensive inves~ 

tigalion the UBA has examined carbon capture and 

storage in terms of sustainability criteria, and has come 

to the conclusion that CCS is a set of non-sustainable 

technologies that can at best represent a transitional 

solution. 

In its position paper the Council for Sustainable Devel~ 

opmeot calls carbon capture and storage a potentially 

important bridge 'to the era of renewable energy sup~ 

plies'. To this end, it believes, CO2 capture technologies 

should be integrated in highly efficient power stations, 

but only from the point of view of economic: efficiency. 

The German government's Advisory Coundl on Global 

Change (WBGU) has taken a firm stance in favour of 

storing carbon dioxide, referring in this connection to 

an 'end-of-pipe technology' that can make a contribu· 

Summary 

tion to climate protection fOf a limited period of time. 

It fejects the storage options in ocean -waters (ccologicaJ reservations and missing long-term effect), biomass (lack of potential for expansion) and saline aquifers (no guarantee of safety and long~tef[rt storage). 

Ex:hausted oil and gas fields could be used temporarily, 

but only if a sufficient retention period can be guaran~ 

teed. In terms of storage period, the WBGU has called 

for secure sequestration for at least 10,000 years. The 

WBGU believes storage under the seabed to be permissible only under certain conditions. The Advisory 

Council on the Environment (SRU) believes tbat car· 

bon capture and storage may be too expensive in comparison with other CO2 avoidance options, and that the 

technologies may also come too late for the upcoming 

expansion and replacement of power station capac:ity. 

Industrial Associations are definitely positive about 

CCS as a long~term option, but often prioritise improving the efficiency of the power station process as a con ~ 

tribution to climate protection. Capture of CO2, as previously mentioned, already offers opportunities for the 

oil and gas industry today. 

(0, Capture Methods 

This investigation of carbon capture and storage in the 

use of fossil fuels has restricted itself to the field of electricity generation in power stations and the potential 

future production of hydrogen by means of coal gas~ 

ification - in othe-r words to plants emitting particularly large amounts of COz centrally (point sources). In 

terms of reducing CO2 emitted through the use of fossil fueLIi, efficiency-improving technologies have previously been the main focus of attention. Applying these 

technologies quickly oyer the past decades has achieved 

a continuous in(rease in power station efficiency 

(despite stricter environmental regulations that have in 

some cases led to increased fuel requirement). The efficiency levels achievable today are 43 % for Iign[te~fired 

power stations and 46 % for coal-fired power stations, 

while for gas-fired power stations 58 % efficiency is now 

possible. For reasons of thermodynamics and materials technology this trend cannot continue forever, So 

a further significant reduction in CO2 emissions from 

fossil electricity generation will require the application 

of CO, capture techniques (which are largely already 

known today) or a move to innovative new power sta~ 

tion technologies that include CO2 capture (e.g. chemi~ 

callo(lping combustion). 

CO2 capture technologies arc more likely to become 

available in the medium term (Iarge~scale application 

is unlikely to occur before 2020) while the development of new, innovative power station concepts should 

be regarded more as a long~term option (see fig. I). 

Disadvantageous for CO2 capture is the high energy 

requirement for the capture process itself, which leads 

to significant reductions in efficiency (in some cases 10 

percentage points and more) and significantly reduces 

Working Group WI, DLR. ZSW, PIK. 
Summary 

Mtl&$ure~ and gl)als for(~ reduction In the power genflltCitlon sector 

ShOrNerm: 

• Effidmy Irl(f€ases 

• (Ol gptufIl from flue g.)s 

Medillf11"unn : 

• tmnhu~tiof1 wim oxyg~n (O~yfuel) 

'Impr(l'(edairsepal'l1tiol'l 

• IGC( with COshift and gas separation 

v.;lh COl absorberor "h membrane 

• Olmhustion with ~'-C01 and 

components for CO, working prO(e~ 

> 

lon9"term : . Newptlwerstabon concepts with 

pwtess-integrated o.'<ygco luppl~ 

sy~erns 

. (~capture wlthoutadditional 

energy reQuirement 

Fig. 1: Measures and goals for COl reduction in the power generation 

sector 

the levels of efficiency achieved today (roughly to the 

level of twenty or thirty years ago). This means that CO2 

capture would lead to a significant increase in electricity generating costs and cause a considerable increase 

in fuel consumption, the logistics of which must also 

be taken into account. For power stations constructed 

around 2020, estimates of the cost of CO2 capture at the 

power station (which dominates the additional costs of 

carbon capture and storage) currently vary between €30 

and €60/t CO2• Various research, demonstration and 

pilot projects aim to Significantly reduce these costs, 

with the goal of bringing the overall cost of the whole 

ces process (including transport and storage) down 

below €20/t CO2, 

From today's (technology) perspective there are three 

relevant options for CO2 capture in the short to medium 

term (see Fig. 2). Flue gas scrubbing will probably be 

an adequate option for retrofitting, especially jf it turns 

out to be possible to reduce the energy required still 

further through new scrubbing agents. Implementing 

integrated coal gasification (ICee) would require 

much grealer availability, which is not yet adequate for 

the power station scale, The crudal point for the oxy~ 

fucl proccss will be to collect experience and success~ 

fully put the lessons learned into practice (e.g, through 

the demonstralion project at Schwarze Pumpe in Germany, launched in 2006 by Vattenfall), 

The method of capturing COl from flue gases in conventional power stations (post~combustion capture) 

is basically available today, but has not yet been dem~ 

onstrated on a commercial power station scale. In 

the longer term this te<.:hnology is unlikely to become 

widely established unless its energy consumption can 

be reduced significantly, 

RECCS PrOJect 

11 

Pre~combustion capture of CO2 in coal~ or gas~fired 

power stations ',ArJth integrated gasification combincd 

cycle (IGCC and natural gas combined cycle, NGCC) 

is from today's perspective a better method than flue 

gas capture of CO,. Apart from its higher efficiency levels, the prime advantage of this technology lies in its 

flexibility both in terms of fuel (coal, biomass, substitute fuels) and in terms of product (electricity, hydrogen. synthetic gas and liquid fuel). The next step here 

is large~scale technical demonstration. The IGee tech~ 

nology itself - without CO2 capture - has already been 

tested in several plants (e.g. Buggenum in the Netherlands and Puerto llano in Spain), Before CO2 capture 

is implemented there will be a need for improvement 

and development "findividual components (e.g. hydrogen turbines}, In Germany RWE Power intends to take 

the first step towards implementing this technology by 

building a full-scale rGCC power station with CO2 capture (output (450 MW gm~ I 360 MW",) by 2014. 

The oxyfuel process (combustion in pure o:rygen) currently offers the best prospects for CO2 capture in terms 

of achievable overall efficiency of the process (and also 

the resulting costs). because it is largely based on conventional power station components and technology. 

It is not yet possible to provide a precise assessment 

because the process is still at the beginning of the dem, 

onstration pbase. At Schwane Pumpe in eastern G(',"r~ 

many Vattenfall Europe is building the world's first pilot 

plant for lignite combustion u5lng the oxyfuel proc· 

ess. The Vattenfall pilot plant, which has an output of 

30 MW (thermal), will be used for research and development purposes with the aim of developing the new 

technology to the point where it is commercially via· 

ble. It is scheduled to begin operation in 2008 after a 

construction phase lasting about three years. Initially 

the CO2 will not be stored, but corresponding concepts 

(e.g, transport options) are being investigated, 

Whether CO2 capture technologies become relevant for 

power station replacement will depend on political and 

economic circumstances. The lack of incentives for retrofitting existing power stations with CO2 capture has 

meant that this option has not been relevant to date. In 

order to be prepared for future developmenls it might 

make sense to build new power stations 'capture ready' 

(prepared for retrofitting with CO2 capture). That dis· 

cussion is already under way, 

'Ihe space required for the additional components can 

place restrictions on the implementation of CO2 capture and storage. Connection to suitable storage and 

transport infrostructul'es is also a significant location 

faclor, 
12 

C02 capture processes 

1) Post·combusdoD 

2)0.)'1,,1 

3] Pre·combu5tion 

fig. I: Methodl of CO, capture at the power It'tion 

(0, Transport Methods 

Because of the considerable transport volumes that 

occur with CCS, the main issue when analysing loca~ 

tions for sources and sinks is to reduce transport dis· 

tances and costs. to a minimum. Case studies show 

that the spedfic transport costs can vary very consid~ 

erably from case to case. Even if the cost of transport 

appears small in comparison with the cost of CO2 cap~ 

ture at the power station, the aspect of cost efficiency 

of CCS-related transport will have to be induded when 

selecting locations for new sources, 

Alongside transport distance, the question of the gen~ 

eral accessibility of the various transport infrastructures that are suitable for CCS is an initial parameter for 

location analysis. Wherever it is possible to use existing bulk-capable means oftransport and transshipment 

facilities there will be potential for reducing transport 

costs, 

From the energy efficiency, economic and ecological 

perspectives the only relevant options for large-scale 

CO2 transport are pipelines (onshore and possibly offshore) and large tanker ships (depending on the location conditions barges or seagoing vessels for offshore 

storage). 'Ihe ad\'antage of the pipeline is that it can 

transport very large quantities of CO2 without interruption at relatively acceptable environmental and 

financial cost But constructing a CO2 pipeline infrastructure would be a time-consuming process and 

would tie up considerable capital; this would only 

Summary 

_ .. research required 

appear reasonable for long-term usage (> 20 to 30 

years). Ships, on the other hand, are more flexible and 

more quickly available, but require intermediate storage facilities and loading/unloading infrastructure. 

With inland waterways the restrictions on availability during periods of low water levels must be taken 

into (:onsideration, Transporting CO,! by road and rail 

tanker is an option only for small quantities and will 

therefore probably only be relevant for the demonstration and launch phase (see Table I). 

The high investment cosls involved make it especially important to coordinate the timing of planning, 

approval and construction of power stations, pipelines 

and CO, sinks. So establishing a CO, infrastructure 

necessitates forward-looking planning and coordination between the different parties involved. 

Unlike the case of pipeline transport, there has so far 

been practically no experience in transporting CO2 

by ship. However, because CO! has similar ph~'sical 

properties to LPG (liquefied petroleum gas), experi. 

coce with LPG transport is partially applicable to CO2 

transport. 

Both the aforementioned transport optiOn!; require gas 

conditioning in order to transport the CO2 in the densest possible form (liquid or super(ritical). Pipelines 

require conditioning to high pressure (approx. 80 to 

120 bar), while tankers require very low temperatures 

at ambient pressme (low-temperature tankers) or temperatures below normal combined with pressure above 

normal (hybrid tankers). 

WorKing Group WI, DLR, ZSW, PIK 
Summary 

Modeof 

transport 

< to 

< 100 

< 1.2 

< 0.5 MIla 

Seasonally appro~.l 

re~trlcled (water 

le~els) 

Always dPprux.1.5 

(function of 

diame1er) 

Always appro~. 5 

R~ .. tri(\ed in wln- appftlk 25 

ter, congestIOn 

Both gas conditioning and CO2 transport require quite a 

lot of energy, normally electricity for compression andl 

or (ooling. According to current knowledge the energy 

required for CO2 compression is equivalent to an efficiency loss at the power station of about 2 percentage 

points (for gas-fired power stations) to 3.5 percentage 

pOints (for coal-fired power stations). This additional 

energy requirement causes additional CO2 emissions. 

Estimates of additional (energy-related) CO2 emissions 

associated with CO2 transport vary greatly, especially in 

relation to transport distance and capacity, Here addi· 

tiona I (energy-related) emissions of 1% 104 % per 1,000 

km are expected for ship transport and 1 % to 2 % per 

1,000 km for pipeline transport. 

The range of average cost estimates for CO2 transport by 

pipeline or ship is between about €l and €lOlt (depend~ 

ing on mode of transport, distance and capacity) and 

represents about a 10 % share of the overall costs of the 

CCS proceSli (comprising capture, compression, lrans~ 

port and storage). In relation to the other infrastructure 

cost~ (electricity transmission, fuel logistics) the cost of 

CO2 transport is likely to be a secondary factor when 

selecting power station sites. Also, el(isting power sta .. 

tion sites are often likely to be retained for reasons of 

public acceptance. 

Already today. fuel (oil, oil products, coal) represents a 

large share of goods transport. Introducing CCS on a 

large scale would increase freight volumes considerably, 

through the supply of additional coal to power stations 

and the removal of CO,. 

Safety statistics for existing CO2 pipelines (in particular in the United States) show a smaller leakage risk 

than for pipelines carrying natural gas or hazardous 

substances; nonetheless, routes should avoid densely 

populated areas where possible for reasons of safety. 

RECCS Projl:([ 

50metimes 

Will almost 

always have to be 

Wl'lstructed from 

scratch (largely 

inve~tmf01) 

Gerltrally 

Always 

B.arges not seagoing, 

time rrslri(\Jons 

25 year operating 

period, hlgher{osts in 

built,upJreal 

NOrse 

((lst, noise and 

emissions, a((ept,mce, 

tim~ rEstrictionl 

13 

Tablet: 

Characteristics and 

suitability of differenl 

modes of transport for 

CO, transport 

In populated areas safety measures against leakage 

and overpressure are required. Although the relative 

risk associated with ship transport is also predictable, 

large-scale introduction of CO2 tankers for CCS would 

increase lhe absolute risk of shipping collisiuns and 

tanker accidents. 

co, Storage Methods and Capacity 

There are various different ways to withdraw COt from 

the atmosphere. A distinction must be made between 

utilisation for technical and chemical purposes (e,g. 

producing carbonic acid, dry ice and feedstock for poJ~ 

ymer chemistry), storage in geological formations (e.g. 

saline aquifers), sequestering CO2 in the marine environment either directly (e,g. depositing it in the ocean 

depths) or indirectly (e.g. algae formation) and with· 

drawing CO~ from the atmosphere by intentionally 

gl'Owing biomass (e.g. forestation). A mineralisation 

process fol' binding CO2 to silicates is also under dis· 

cllssion (especially in the United States) but it 15 still in 

the early stages of development and is associated wilh 

vcry high energy requirement and very large amounts 

of material to be disposed of. Fig. 3 shows an overvie'",' of storage projects currently under way across the 

worfd. 

For various reasons the storage possibilities for CO2 

are restricted at both the national and global levels. The 

many W1certainty factors lead to it very wide range of 

estimates about the extent of existing capacity, and the 

same applies to the question of the fundamental suita~ 

bility of the various storage options, where ultimately a 

case~by·case analysis will be required to obtflin prfl.cti~ 

caUy relevant resulls. 
14 

CO, storage projects operating wo~dwlde 

50 add gas injection facilities In 

North America 

• ECBM· project 

Q £OR .... project 

• Gas production held 

o Saline aqutf~r 

.. EnhMcffl (oal Bed Methane 

( :::: deep (Qat seam;) 

*10 Enhanced Oil RwV'!!y 

fig.3: (0, storage project. operating woridwide (lEA database) 

Estimates made in 2004 put global storage potential in 

the range between 476 and 5,880 Gt CO2 (with a prob· 

able potential 0' 1,660 Gt CO,). By comparison, global 

CO2 emissions i:l2005 were 27.3 Gteoz' This shows that 

the potential of CCS is certainly considerable but that 

regardless of other factors, the limited storage capacity 

alone means that it will not be Fossible to achieve a last~ 

ing ,olution to the climate problem through CCS. Table 

2 shows the storage capacity and a selection of assessment criteria, for the example of Germany. 

According to currcnt information the theoretical storage potential in Germany is between 19 and 48 Gt CO2, 

The largest and - in view of the numerous as yet unrcsolved issues affecting storage in deep coal seams (e.g. 

concerning permeability) - most important share relate~ 

to deep saline aquifers, supplemented by the more limited possibilitie5 for storage in depleted gas fields. A calculation focusir.g on these two storage options and taking into account an average extra energy requirement 

for CCS of30 % comes up with a static range of between 

thirty and sixty years for CO2 point emission sources in 

Germany (2005: 393 Mt/a).' 

In principle the storage of CO, in geological structures 

can draw on many methods and technological procTaken together Ihe~e two storage options have a potential of 143 

to 30.5 Gt CO2 

Summary 

esses currently in usc in the oil and gas industry and 

in the disposal of liquid wastes, However, drilling and 

injection methods, computer simulations of the distriimtion of gas in reservoirs and monitoring methods will 

have to be adapted to the special requirements of CO2 

storage. Here there is still a great need for researcb and 

development. In Germany the Ell·funded C02SINK 

project will significantly increase knowledge about the 

behaviour and controllability of CO2 in underground 

reservoirs. 

Criteria for a Systematic ASSl!ssment of CCS 

A systematic comparison of various ces technologies 

with other technology options such as energy efficiency 

and renewahles requires a comprehensive catalogue of 

criteria. The criteria used here can be categorised as fol~ 

lows: 

Ecological criteria 

• Environmental impact as per life cyde assessment 

(LCA) 

• Energetic efficiem:y 

• Other ecological impacts, ecological restrictions, 

consequences and risks (direct and indirect) 

Working Group WI, DLR. ZSW, PIK 
Summary 

Peep (oaheams +(+) 

3.7-16.7 

Depleted oil fields 

I 

0,11 

5.lltci'lverns 

0.04 

Disused coal mines + 

0.78 

+ 

+ ++ ++ 

k. A. + 

+ 

lS 

Table 2: 

Assessmenl of geological storage options 

in Germany using 

selected criteria 

(OSI ~sllmale(Qnt3ins only storage <osts without capture, compression ¢r transport (i1fter HOFYS 2004, BGR, authors' additions) 

Figuresafter May ~1 ai, (2005) 

Criteria: 

Nf'9dtl~e or ~ry probktnJti( 

- Futld{\m~ntal dlfflOJlucs still eXist, but may be msolvQble 

+ G()od. orf~w obmdes 

+ + Vrrygond 

Parenthese~ mdK.3te unccrraimies or places where each individual ca5pwill have to be assessed 

Economic criteria 

• Generation costs and CO2 avoidance costs 

(specific investment costs, resulting electricity and 

hydrogen production costs) 

Other criteria 

• Timeframe for application (possible time of implementation) and market readiness and/or R&D still 

required 

• Compatibility with power plant replacement needs 

• Acceptance 

• Compatibility with existing structure and possible 

future development trajectories 

• (Technological) stimuli for global climate protec 

Lion 

• Industrial policy opportunities 

.. Transferability to developing countries (not appli· 

cable for Germany) 

., Compatibility with other climate protection strate· 

gies (decentralised options) 

• Impact on import dependency 

• Security policy implications 

RlCCS PrOject 

Comparative Life Cycle Assessments 

For the ecological c\'aiuation of selected system configurations (process chains from natural gas and coal to 

low· CO2 electricity and hydrogen) the life cycle assessment method (LCA) defined by ISO 14.040ff was used. 

This integrative approach analyses the material and 

energy flows required to produce a kilowatt· hour of 

electricity or hydrogen and calculates their environ~ 

mental impact. 

For eiectricit)' gencmtion the environmental impact of 

the following fossil fuel conversion paths were lnves, 

tigated; post-combustion (with coal- and lignite-fired 

thermal power plant and natural gas CC), pre·combustion (coal-fired IGCC) and oxyfuel (with coal). TI,e Ruhr 

region (a densely populated industrial region in western 

Germany) was selected as the location of the power stations and an empty gas field 300 km away in northern 

Germany as the sink. For purposes of comparison with 

renewable energy paths, electricity gencrah~d by solar 

thermal power stations (in Algeria) and by , ... ind power 

(in the German North Sea) was also modelled. In order 

to have the same reference location as with the fossil· 

fuelled options, the electricity was assumed to be transported to the Ruhr region using bigh·voltage DC lines. 

The following central conclusions can be drawn: 
16 Summary 

9 COl"eql Coal-fired PP 

kWhel rif:49%-> 40%138% 

lIgnile-firoo PP 

eff:41S%-::d4% 

Maturalgll$ (( 

eff:60%-> 51% 

Coal·fired IGee 

eff: 50%-> 42% 

VIlO 

WI) 

800 

100 

@ 

500 . 

400, 

300 

100 

100 

o 

C\lill·fired (iJjl-flr1!d Coal-tired Lignitepp PP ... i1hCCS 0xyI'ue1 fifl'!dPP PPwhbCCS 

l~oltHired 

rpwlth«S 

NatUral 

galee 

Nal'\lralga! 

(CwhbC(S 

IG«( 16" 

wlthC(S 

, "'! II Upstream 

• Power Plant (PPI 

: CI capture & Liqu~fadio, 

Ifill Transport 

; Ii Storage 

Fig. 4: LCAs of ees plant in comparison with selected renewables (here: greenhouse gasesl 

The high rates of CO2 reduction generallr cited in the 

CCS discussion (capture rates of88 % and more) relates 

only to CO2 emissions directly in power station oper~ 

atiofl. If we take a holistic approach, 5 % of the CO2 

emissions already oo;::ur in the supply chain both with 

coal-fired thermal power stations and with natural gas 

CC. Reduced efficiency also causes higher consumption 

of primary energy and thLis a 'larger' coal or natural gas 

supply chain, Taken together, these factors mean that 

with a capture rate of 88 % actual CO2 emissions can 

not be reduced by 88 %, but only by 72-78 %, In view of 

this fact it is unjustified to speak of 'C02~free' or 'zero~ 

carbon' power stations. Even if the capture rate at the 

power station can be increased still further in future, 

the designation 'JOW~C02' is more pertinent.2 

The discussion to date has also neglected to consider 

that greenhouse gas emissions as a whole - and not only 

CO2 emissions have to be reduced, The Kyoto Protocol 

requires Germany, for example, to reduce a total of six 

greenhouse gases (and not just CO,I by 21 % by 2012.lf 

the effects of CO2 capture on greenhouse gas emissions 

are calculated, it is found that the potential reduction is 

less than proport:onaJ. For example, with a CO2 capture 

rate of 88 % (at the power plant) greenhouse gases as a 

whole can only be reduced by 67-78 % (see Fig. 4)3 The 

reasons for this are again the considerably increased 

prirnar)' energy consumption a.nd the methane emis M 

sioos associated with fuel extraction and transport, 

which can be relatively high depending on the fuel and 

its source, Under the given assumptions these have a 

2 F'ot exumple, future capture rate~ o{up to 99.5 % are expeded 

through the oxyfl.lcl process. for a coul" fired power statIOn this 

would result in u net CO2 reductIOn of 90 to. 

3 Even with the oxyfuel method the net greenhouse gas reduction 

for a coal· fired pov.'er station would not be greater than 78 % 

(desptte the hlghcr capture rate of99,5 %). 

disproportionately large impact on the greenhouse 

eflecl. Improvements in the supply chain (e.g. collecting 

and using mine gas) could strongly improve the results. 

From a holistic perspective this lessens the reduction 

achievable through CCS power stations. With 396 g 

CO2 equivalent per kWh the 'best' power station (in 

climate terms) without CCS (natural gas CC) has only 

51 % more greenhouse gas emissions than the 'worst' 

power station with CCS (coal-fired thermal power sta~ 

tion with 262 g CO, equivalent pel" kWh). Of all the 

fossil~fuelled power stations considered, oxyfuel prOM 

duced the best greenhouse gas results under the given 

assumptions. Physical capture of almost 100 % of the 

CO2 allows net rates of reduction of90 % for CO2 emissions and 78 (~h for greenhouse gas emissions, 

Fig. 5 shows this in comparison with selected technologies from the field of rencmbles, whose impact by contrast are very small (resulting from manufacturing of 

the plantl. 

Overall, CO2 capture requires additional energy conM 

sumption of20 to 44 %, depending on the process, The 

higher energy consumption is felt directly and proportionately in various impacl categories in the LeA, 

This applies, for example, to photo-oxidant formation, 

eutrophication, acidification of soil and water, and particle emissions (PMIO). On the other hand, individ~ 

ual emissions such as S02' N02 or dust are reduced 

through reactions with the solvent, which in overall 

terms causes .-1 reduction or at least a reduced increase 

in individual impact categories. Pig. 6 shows this effect 

for the example of the modelled lignite~fired power sta M 

bon (post~combustion). 

The 44 % increased energy consumption initially causes 

a proportional increase in all impact categories. But 

overall the aforementioned influences callse a reduction 

Working Group WI. DLR. 11W. PIK 
Summary 17 

Fig" 5: 

9 C02"eq/kWhtl 

1,000 

900 

}l BOO 

700 

CSP: Concentrating solar thermal power plant 

«(: Combined (ycle 

Compari50n ofgreenhouse 

gas emissions from (C5 

power stations with selected 

plant from the fields of 

renewables and advanced 

fossil-fuelled CHP technologies 600 

CHP: (ombinj!d he",t 3nd powr 

500 0: Germany 

400 

100 

10O 

100 

Coal/lignite Natural gas CC Wind! Nfttural9a~ Natural Electrlcltymlxscenario5 

wlthol,ll «(5 with «(5 without ((S with (cs CSP COOP gas (UP 02050 EU 2fJ50 

of 3 % in the acidification calegory, and PMIO equiv-

.lients rise by only approx. 24 %; on the other hand 

eutrophicalion rises by 40 % and photo-oxidant formation by 524 %" 

A comparative analysis, however, showed the inves~ 

tigated renewable energy options to have considerably better values than the fossil-fuelled power stations 

with CO2 capture. Even when electricity transmission is 

included, the CO2 emissions, greenhouse gases (sec Fig, 

4) and cumulative energy demand of solar thermal electricity and electricity from wind power is just 2103 % of 

the corresponding figures for fossil·fuelled CCS pla.nt. 

For hydrogen production tbe environmental impact of 

steam reforming of natural gas and coal gasification 

were investigated, The Ruhr region was again sdC\.:ted as 

(NaH) (2"{) 

the location. Renewable hydrogen production was mod~ 

cUed as electrolysis using electricity from solar thermal 

power stations in Algeria and offshore wind farms in 

the North Sea (as modelled for electricity generation). 

The location for electrolysis was the Ruhr region; again 

high~voltage DC lines were used for transmission. TIle 

following central conclusions can be drawn: 

As with the case of power stations, we cannot speak of 

'C02-free' production of hydrogen, It would be more 

pertinent to use the term '!OW~C02' hydrogen, When 

the supply chain is taken into account, even with a caph 

turt' rate of 88 % (coal gasification) it would only be 

possible to reduce CO2 emissions by 81 %. 

With natural gas steam reforming, reduction rates of 

only 39/52 % (CO, emissions, depending on different 

III U~stream • Power plant (PPJ Cl Capture & liquefaction iii Trilmport 1m Storage Fig, 6: 

Comparison of other impact 

categories for lignite-fimd 

steam power station without 

and with CCS (postcombustion) 

0.30 

027 

0.24 

0.11 

0.18 

0.15 

0,11 

O,O! 

0.06 

Photo-oxidant formath;m Eutrophication 

Ig fth~n,eqlkWheIJ (g POl:eqIkWh~IJ 

+524% . 

Ml /"_ 0"00 .... ___ _ 

Addlfication PM1G-equiYlllents (urn. energy demand 

[10, 9 SOf~q/tWhelJ [10· g PM10-fq/kWhejl [kJ·100,OOoJkWhtll 

lignite· llgnlt~·fired lignite- lignite·fired lignite- Lignite-fired Lignite- li9nil~·1ir¢d lignite" Lignite-rued 

fired PP PP With ((S fired PP PP with CCS fjred PP P~ With (5 fired PP PP with «S fired PP PP with CCS 

REC(S PrOINt 
18 

reforming technologies) and 36/49 % (greenhouse gas 

emissions) are possible from today's perspective, if it is 

assumed that only the COl emissions from the synthe~ 

sis gas can be captured at reasonable cost, and not those 

that occur beforehand when natural gas is burned to 

produce process heat. 

Other Ecological Assessment Factors for ((5 

The systematic approach of the LeA does not cover 

every ecological criterion. As well as direct and indi~ 

reet influences on the landscape (e.g. through increased 

fuel usage) and tbe negative consequences of increased 

transport volume through the construction of a CO2 

infrastructure, the greatesl impact would result from 

the possibility of unplanned release of stored CO2 and 

the direct influence of the stored CO2 on the surround~ 

ings of the sink over the course of time. 

The various storage options differ - in some cases considerably - in terms of ecological and safety aspects. 

The risk of leakage is present in all geological storage 

options. Whereas storage in exhausted oil and gas fields 

and use in oil production (enhanced oil recovery, EOR) 

appear relatively safe for the population and the envi~ 

ronment, injecting CO2 into disused coal seams could 

pose considerably greater risks. Saline aquifers are 

regarded as relatively stable long-term sinks, although 

there is still a great need for research into the underground movement of CO2 (mechanisms of di.ssemi~ 

nation and activity). Such aquifers have so far generally only been explored in the vicinity of hydrocarbon 

deposits so there is a shortage of comprehensive data 

and a.o;sessments of their petrophysical properties. The 

introduction of CO2 leads to acidification of the water 

in the aquifer. Through its corrosive properties the 

acidic water codd cause changes to the surrounding 

strata (especially carbonates) and to unprotected borehole seals. 

The use of deep (currently uneconomic) coal seams 

bears the ecological risk of the extracted methane escap~ 

irlg (methane is a considerably more potent greenhouse 

gas than COz' by a factor o(21), 

Marine storage options are associated with very great 

uncertainties and risks, Direct cause and effect rela~ 

tionships have so far only been demonstrated in certain cases, Acidification of seawater shifts the carbonate equilibrium: the shells of calcifying organisms 

become thinner and can even dissolve, interrupt. 

ing food chains or at least altering them with ines~ 

timable consequences. CO2 lakes on the ocean floor 

affect more than the local ecosystems. MallY aspects 

of the behaviour of the ocean floor - submarine slides, 

undersea quakes, etc. - may be understood, but they 

remain unpredictable. Fundamentally it must be noted 

that storage in the oceans would not lead to permanent 

sequestration of the CO2, Dissolving CO2 in the ocean 

depths leads to delayed re-emission into the atmosSummary 

phere after a few hundred years at the latest, when oce~ 

ank circulation brings the water masses into contact 

with the atmosphere again. In view of the undarified 

consequences of marine storage options they are categorically rejected by the environmental organisations 

and are being pursued in any form in only a very few 

countries (in particular Japan). 

Fixing CO2 in biomass by planting forests and growing mOl1ocultures brings with it multifarious ecological 

problems. It must also be emphasised that this form of 

storage is only a temporary one, with delayed rdease. 

''\Then a period of several generations is considered, the 

reduction effect is nil. Additionally, monocultures displace other species and alter biotopes. 

The construction and operation of renewable energy 

technologies e.g. constructing wind farms, hydroelectric dams and solar thermal power stations - can in 

certain cases be associated with considerable ecologi" 

cal consequences and disfiguration of the landscape. 

Within a social and energy system guided by sustain~ 

ability principles, decisions would have to be made 

about which interventions are acceptable for the population and the natural environment and which should 

be avoided. vVhereas the impact of using reneVo.'ables is 

largely known and understood, decision-making with 

re<;pect to ces is from today's perspective still ham~ 

pered by numerous uncerlainties and open queslions, 

Economic Comparison of ((S and Renewables 

If the capture and stomge of CO2 emissions from fos~ 

sil~fuelled power stations can be demonstrated successfully, electricity generating costs (at power station) of 

between 6.5 and 7 ct/kWh can be expected on the basis 

of CCS power stalions commercially available in 2020 

(interest rate 10 %/a). In view of the fud price rises 

expecled in the longer term, a further rise in costs to 

between 7 ct/kWh (coal) and 8 Cl/kWh (natural gas) i, 

probable by 2040, In coal-fired power stations the fuel 

price effects could potentially be largely balanced out 

by further technical progress. Our calculations put CO2 

avoidance costs at between €35 and €50/t CO2 in 2020, 

when the same power station without CCS is taken as 

the reference for comparison. Here coal-fired power stations are towards the bottom end of the range, gas-fired 

towards the top. This is less than the cost range assumed 

today and assumes that significant learning processes 

'will already have occurred by then, but is still signifi~ 

cantly higher than the costs of about €20/t COz that the 

energy business is aiming at for the process as a whole. 

Rcncwables, which on the basis of a representative 

mix - today still involve electricity generating costs of 

approx. 13 to 14 ct/kWh (again assuming inlerest rate 

10 %/a) can also achieve that level of cost, by 2020 if 

their market introduction continues at a similar pace 

to now. With a continuing global increase in market 

penetration and learning effects significant cost degres~ 

Working Group WI. DLR, ZSW, PIK 
Summary 19 

Electridty generating (osts In (tlkWh 

DLR 100S price forecast with CO, penalty; Interest rate 10%/a 

14,-----~~------------------------------------------------------, 

11 

(jp Coal·fired I(iCC with ces o (oat-firedstfJam turbine without «S 

1i& Naturill Gas « with (eS 

Nallllilt Gas ( without (es 

• Natural Gas CC without «S (EWI2005) ,01r---------'---.. ----~~------------------------~O~C~'~al.~fir=.d~st~ea=m~1U~rb~in~'w=i1~ho~uf.lc7.cs~IE"WWll~OO"5"1 

Wind offshore 

.......... , 

o -J------'------"r"'-----"--___ ,--____ .J...... ____ ,--____ .J...... ____ ,.-___ -'--__ -I 

2000 2010 2020 1030 1040 1050 

Fig, 7: Development of electricity generation costs (for new plant) for renewablel, conventional gas· and coal· fired power stations and eCI power 

stations, fuel prices after "OLR 2005" and foreonventlonal power stallons without ces after EWI lOOl given for comparison 

sions can still be expected for renewables in future, so 

that by 2050 the level of costs for generating electricity 

from renewables in the characteristic mix under COllw 

sideration could fall to 6 ct/kWh, Individual technologies could achieve electricity costs of approx. 4 ct/kWh 

if a continuing expansion of global markets allows the 

learning wrv!;' to continue to be exploited (see Fig. 7). 

If the pace of expansion of rcnewables in the electricity se(tor remains fast - as in the various scenarios that 

describe a switch to a climate-friendly energy supply 

based on a combinution of stepping up the expansion of 

renewables and energy efficiency (e.g. the Naturschut· 

zpJus scenario) - at the time when the first CCS power 

stations might be coming on Slream some technologies 

(e,g, wind offshore) could already be offering cheaper 

electricity generation costs and further increase that 

advantage over the course of time. Here significant 

cost·redtJClion effects come through the global market 

effects, so even jf renewables in Germany were to grow 

less dynamically, cost parity between CCS and individual rcnewables can be expected. Only if fuel price rises 

'''''ere to be very small or cost reductions in the CCS 

process were to surpass the foreseeable effects would the 

situation be more favourable for CCS plant This would 

not negate the general effect, but would push back the 

point on the time axis where renewable~ become relatively competitive. 

Under the given assumptions there is neither a compel~ 

ling economic reason to give CCS tel:hnologies pre(er~ 

enc€' over a further expansion of renewables for elecRECCS ProWl 

trkity generation. Nor, though, do they r~present a 

prohibitively expensive option and if successfully commercialised under suitable conditions (inexpenoivc, 

stable long-term storage options, good infrastructure, 

cheap coal) could become part of the future electricity 

generating regime in some world regions. 

Tn an economic comparison of low-C02 and largely 

C02~free options for hydrogen production (CCS versus 

renewables) the fossil option comes off best. By 2020 

hydrogen from coal gasification with CO2 capture will 

cost approx, €1250/G/ (450 c,/kWh, upper heating 

value, at plant), or about twice the cost oftoday's hydrogen from natural gas reforming. Further fuel price rises 

until 2050 increase the cost to about € 14/GJ (5.04 etl 

kWh). Only electrolytic hydrogen via electricity from 

cheap hydropower can compete with this, but the available capacity is small. Only in the longer term costs of 

around €16~t8/GJ for electrolytic hydrogen from wind 

or solar electricity can be expected; around 2020 the 

cost will probably be about €19-20IGJ, In the medium 

term the cost of generating hydrogen will always be at 

least double the cost of natural gas. So for economic rcasons hydrogen will not be implemented as a fuel before 

2030, Regardless of the way it is produced, it will proba· 

bly be several decades before hydrogen becomes impor~ 

tant in the energy sector in relevant quantities because 

of the considerable infrastructure challenges associated 

with its introduction. 
20 

The Role of (CS in Industrialised Countries - the 

EKample ofthe German Energy Supply System 

In this study three different scenarios were developed 

for the future energy supply in Germany (as a representative industrialised country) in order to analyse 

the role of CCS in the energy sector in comparison to 

renewables. In all three scenarios energy-related CO2 

emissions were reduced to 240 million tla by 2050, 

which corresponds to a reduction of about 75 % compared with 1990. The scenarios are based on the following assumptions: 

• CCSMAX: CCS as the main element of a climate 

protection strategy with 'maximum' use of CCS 

technologies within the framework of a development that otherwise largely follows current trends 

for energy consumption and expansion of renewabIes (relatively small mobilisation of efficiency 

potentials, limited implementation of the expansion potentials of renewables). 

• NATP: Concentration on across-the-board exploitation of energy saving potentials and vigorous 

expansion of renewable energy technologies, as 

described in the 'NaturschutzPlus' scenarios prepared for the Federal Environment Ministry (after 

BMU 2004 and BMU 2005). In this scenario CCS is 

not required, 

• BRIDGE: CCS as a bridge to further expansion of 

renewables while at the same time increasing energy 

efficiency and expanding renewabJes more strongly 

than in the reference case but less than in NATP. In 

this scenario the two strategy elements are insufficient to achieve the climate target unaided, so the 

use of CCS is required. 

Various key findings can be drawn from the scenario 

analyses. Emission-reducing measures in the field of 

electricity generation alone will simply not be enough 

to meet tbe climate protection target. Similarly comprehensive measures in the heating and vehicle fuel sectors 

are also required, As well as expanding renewables, the 

exploitation of efficiency potential will have to make a 

very considerable contribution. If greater use is made 

of fossil resources, the alternative of generating hydrogen by gasifying coal with carbon capture and storage is 

always an option. 

As the main element of a climate protection strategy 

CCS runs into structural and capaCity limits (CCSMAX 

scenario). The earliest date when CCS technologies are 

expected to be ready for implementation is 2020, which 

is too late for the first wave of the power station replacement needs, which has just begun. This scenario would 

necessitate extremely rapid growth rates for CCS plant 

between 2020 and 2050 and speedy establishment of a 

hydrogen infrastructure. With 5,900 PJ/a the demand 

for coal in CCSMAX rises to three times today's level. 

By 2050 hydrogen would be the dominant form of 

energy, supplying 47 % of final demand. The amount of 

Summary 

CO2 to be captured and stored in 2050 would amount to 

about 600 million t CO,/a (Fig. 8). At that level the storage capacity available in Germany would last for just 

one or two decades. Cost advantages for energy pro~ 

duced using CCS are either non-existent (for electricity) or marginal (for hydrogen) so there is no decisive 

economic incentive for such a prominent preference for 

CCS. The high level of funding already required today 

in the form of R&D and demonstration plant for such a 

strong expansion of CCS technologies would probably 

demand a major turn away from support for efficiency 

strategies and strategies for expanding renewables. A 

great challenge in view of the very many questions that 

are still open is that the lead times involved mean that it 

would be necessary relatively qUickly to achieve a very 

high level of certainty about the ecological impact and 

long-term stability of the potential CO2 sinks. 

A climate protection strategy following the NATP see· 

nario, which manages without CCS, would not yet 

develop of its own accord. As well as maintaining the 

current dynamic rate of expansion of renewables in the 

electricity sector and extending their use to the heat sec· 

tor on a Significant scale, considerable additional sup· 

port measures to encourage much greater efficiency in 

use and conversion of energy would be required if the 

2050 climate protection larget is Lo be met on time by 

this strategy. Expanding renewables and increaSing efficiency are measures that take effect relatively quickly, so 

as long as the necessary support measures impact fast, 

they allow the restructuring process to run more harmoniously than in the CCSMAX case described above. 

Major conversion of energy infrastructures would be 

required, but this could be realised in stages. A strategy 

concentrating especially on energy productivity also 

makes sense in broader economic terms because many 

of the efficiency measures represent the most economic 

option for climate protection regardless of what measures are taken on the supply side. If external costs were 

included the overall economic situation would be even 

more favourable. To that extent this scenario represents 

an 'ideal strategy' but one which demands that very 

effective energy policy decisions be taken quickly, especially a clear rationalisation and expansion of energy 

efficiency policy. In the longer term this scenario necessitates considerable structural changes, increasing the 

network and system integration of renewables on the 

electricity side, integrating energy import structures 

(e.g. electricity from solar thermal power plant in North 

Africa) and greatly expanding district heating systems. 

To pursue both strategies 'at full steanl' until 2020 (efficiency and expansion of renewables following NATP 

until 2020; CCS development as in CCSMAX), but then 

to largely drop one of Lhe options would not seem to 

be a sensible way to proceed. Consequently, the third 

scenario discusses the extent to which the two strategies could be combined compatibly in a forward-looking strategy. 

In a development corresponding with the BRIDGE scenario the timeframe for introducing CCS technologies 

and a hydrogen infrastructure is more relaxed than in 

CCSMAX because until 2030 the contribution required 

Working Group WI, DLR, ZSW, PIK 
Summary 

(02 reduction scenarios for Germany ~ RerwwiJble$ 

II Natllral9i\s 

1'1 Mineral oil 

Primary energy, PJ/a 

14j)()0 

12,000 

10,000 

8,000 

6,000 

4,000 

1,00) 

2000 200S co~ CCSMAX 

storage 

in mio.l/a: 586 

from this option (.HI remain relatively small. In the 

event that CCS technologies turn out to be a sensible 

and ecologically sustainable energy option, even the 

level of expansion required by 2050 does not encoun~ 

ter any fundamental barriers concerning required plant 

capacity, infrastructure modifications or sink capacity. 

In this case about 330 million t C021a wOl1ld have to 

be captured and stored in 2050. For this, however, fos· 

sil~fuclled power stations built before 2020 must also 

be 1;iuitable for retroJitting with CCS, if the electricity 

sector is to make a ~ubstantial contribution to reduc~ 

ing CO;;:, This should be taken into account in current 

ongoing power station planning, and where possible 

plant should be designed to be 'capture ready', 

An energy policy following the BRIDGE strategy will 

definitely demand a general intensification of energy 

policy in all the listed field, if long-term climate protection goals are seriously to be achieved, So including 

'CCS technologies' as an additional climate protection 

option should not serve as an excuse for neglecting the 

strategy clements of 'energy efficiency' and 'renewables' 

as the process intensifies. Instead these ~holiid be mobi~ 

Used by 2020 at least to the extent that they can con~ 

tinue to 'take oW thereafter ifCCS technologics should 

turn out to be unworkable on the desired scale in the 

RECCS ProJI?(I 

IlilI (oalfur((S'Ii, 

III ligni1e • Nuclear 

BRI])IlE NAIP 

328 

21 

Fig, 8: 

Pom"yenergy 

structure today and in 

the lce,a,iol for 2050 

energy sector. At the same time, this timeframe offers 

the opportunity to explore the development and cost 

potentials of CCS technologies thoroughly and without 

massive pressure of time, BUl the successive introduc~ 

lion of CCS <::ould help as an ancillary element to make 

it easier to maintain the sustained impetus for further 

efficiency increases and a greater expansion of renew" 

abies than would possibly be the case with the significantly higher hurdles in the NATP scenario, This could 

identify ways to soften resistance and to offset obstacles 

that remain insurmountable despite massive support 

and energy policy intervention, In view of the real con~ 

stellations of interests and different evaluatiOils of technology options in the field of energy, especially in the 

global context, a development following the BRIDGE 

scenario can be regarded as a 'pragmatic' strategy. 

A cost comparison of renewables and CCS technologies 

for electricity and hydrogen production shows no economic advantages for the CCS option at the point of 

its possible introduclion around 2020. The latter would 

then require CO, prices between €40 and €SOlt CO, if 

it is to be attractive to private investors in place of conventional electricity generation from fossll fuels. Even 

after 2020 renewable energy technologies will probably 

continue to have exploitable cost degression potentials, 
22 

whereas the cost of generating electricity from coal with 

CCS will probably remain roughly constant, assuming 

a corresponding degree of technical development. If we 

factor in the external costs, we find further advantages 

for the development path building on renewables and 

energy efficiency. From today's perspective, the relative profitability of CCS and renewables is associated 

with diverse imponderables. The above assessments for 

rene".'ables work on an assumption of dynamic global 

market developments allowing very considerable cost 

degression potentials to be exploited via mass production and learning curve effects. 

One obstacle to a comprehensive CCS strategy could 

also be lhat a strategy building largely on CCS would 

require the earlier introduction of (Iow·C02) hydrogen 

on a bro~d s(ale, which is associated with great infrastructure challenges, whereas a strategy orientated on 

NATP would not require this on an appreciable scale 

until the middle of the century. 

From the aforementioned aspects it follows that a rigorous strategy based on the NATP scenario could also 

represent the more favourable option in broader economic terms in the medium to long term and $hould 

thus be the aim of energy polky. At the same time, it 

would be recommendable to continue to subject the 

CCS option to thorough scrutiny and in particular a 

realistic practical demonstration, in order to possess 

after a decade more precise knowledge of the potential 

and limits of this set of technologies. [f it then turned 

out that in terms of efficiency and expanding renewables the restructuring of the global energy supply can 

'only' proceed at the intensity described in BRIDGE, 

then CCS would be available as an additional climate 

protection option. 

Requirements for Successful International 

Implementation of C(S 

rlhe concluding part of the study broadens the perspec~ 

tive to examine whether CCS is necessary from a global 

perspective in order to meet ambitious climate protec~ 

tion targets and how an institutional framework can be 

established to sensibly regulate the risks of CCS. 

The role of CCS in the context of other technology 

options ~ i.e. in particular the expansion of renewables 

- was analysed by meanS of an economic scenario analy~ 

sis. Models to maximise global social welfare for a given 

limitation of the atmospheric CO2 concentration were 

chosen by simulating the progress over time of implementation of the three named options (and in the process including the technological learning effects). Central uncertainty factors that have a strong influence on 

the implementation of CCS and on the costs of climate 

protection were identified and interpreted by means of 

sensitivity analyses: 

SumlTlary 

• Learning rates for CCS and renewables influence 

the cost reduction curve of the technologies and 

thus: their application. The qUicker the cost-cutting 

potential of renewables is reaUsed and the slower 

that of CCS takes effect, the less CCS will be used. 

However, in both fields of technology as yet llnfore~ 

seeable development leaps and costs that cannot 

be reduced through learning effects (e.g. for fuels) 

could have a strong influence on their respective 

future market shares. 

• Leakage rates (quantifying the slow escape of CO, 

from storage formations) must be well below 0.1 % 

per year if CCS is to be used efficiently at all. 

• The discount rate determines the weighting of consumption over the course of the planning period. 

If a high discount rate is chosen - giving welfare 

in the present a higher weight and consequently 

resulting in less being invested in renewables - CCS 

gains and greater use of renewables is shifted back 

to a later date. This occurs above all when realising learning rates in renewabJes requires high iniw 

tial investment compared with CCS. 

G The rising cost of exploration and extraction associated with possible shortages of fossil reSOurces 

has a strong effect on the role of CCS. BecaLlse of 

the attractiveness of fossil fuels, if their costs of do 

not rise until relatively lale, CCS will be used exten· 

sively in order to meet the set climate protection 

target at all. But under 'peak oil' scenarios, which 

predict rapidly rising costs due to depletion of oil 

reserves, the substitution of various fossil fuels 

could occur considerably earlier, which would 

reduce the demand for ces, However, the timeframe and interrelationships of these effects are not 

yet fully understood. 

" The use of CCS is worthwhile even if the time 

when CCS technologies become available for largescale application is delayed by several decades. But 

if CCS were not available until 2050 the amount 

of CO2 stored to meet climate protection targets 

would be reduced considerably because it would 

then be more worthwhile to step up implementation of renewables from the outset. 

The outcome of the economic scenario analysis is that 

at the global level CCS can make a tangible contribution 

to meeting ambitious climate protection targets. CCS 

can fulfil a 'bridging function' of a.voiding emiSSions 

on a scale that renewables and efficiency improvements 

cannot achieve on their own, and in that context the 

two technology options can complement one another, 

There can be no doubt. however, that in the long term 

a sustainable reduction of climate change is achievable 

in the energy sector only through renewables and high 

energy efficiency. 

Working Group '~n. D~R. ~SW, PIK 
Summary 

Overall, according to the calculations, keeping the 

atmospheric concentration of CO2 below 450 ppm over 

the course of the twenty-first century could be achieved 

with a relative loss of 0.6 % of global GDP compared 

with the businc&s~as~usual trajectory. in the process 

of which a lotal of approx, 456 Gle (or 1,672 Gt CO2) 

would have to be captured and stored. These results 

should be understood as plausible mjJ~rangc figures -

assuming a leakage fate 0[0.05 % per year and a learn~ 

ing rate for renewables of 15 %. ~fhe precise figure for 

cUlilulative storage and the cost reduction will depend 

on the development of the investigated uncertainty file> 

tors. The model calculations show thal with a combi~ 

nalion of both measures (renewables plus increased 

efficiency a~d CCS) it would be possible to a.chieve 

ambitious global climate protection targets at a rela~ 

tively small toss of economic grO"'-'ih, 'lhe calculated 

growth losses are relativised still further if the necessary 

investments in measures for adapting to climate change 

are factored in. 

Large-scale introdu<.:tion of CCS presumes the implementation of an institutional frarnework that sensibly 

regulates the risks of CCS and offers incentives to use 

the safest possible storage options. 

b.·tany details of the national and international legal situ~ 

atian have yet to be darified, and special frameworks for 

CCS have yet to be developed. Tn view of the long~term 

nature of e02 storage, tbe principles of environmental 

law require legislators to ensure there are suitable rules 

for dealing with future risks and to strike a suitable balance between business liability for harm caused and the 

ultimate responsibility of the state. Monitoring sinks 

and defining an appropriate leakage rate are particularly important here. BecaLlse of the transfrontier effects 

ofeeS, international agreements are impC'ratiVE'. 

As the economic analysis shm ... 'ed, it makes sense to 

embed CCS in international climate protection agreements. However, CCS is not yet included in the mechanisms of the UN Framework Convention on Climate 

Change. Guidelines for accounting fur the emissions 

saved through CCS (and those that may be released 

again) have not yet been implemented. That would be 

an important precondition for being able to include. 

CCS in the tlexiblt' mechanisms of the Framework Convention on Climale Change. With regard to the debate 

between the two fundamental approa(hes to climate 

protection agreements (cap and trade system and techn(')iogy protocol) C(5, with its technological challcnges 

that are yet to be mastered, could serve to illustrate that 

both approaches are possible and usefuL 

Regulating responsibility for risks from ecs could 

be achieved through tradable (arbon sequestration 

bonds, which the operator of, CCS project would be 

obliged to purchase and which would be depreciated 

proportionatel)' if leakage occurs, The bond system 

offers incentives for eJl1cient limitation of harm caused 

by CO2 leakage and involves the financial markets and 

RECCS Project 

23 

through them the public (via investment decisions for 

safe CCS projects) in the control of risk::>. State revenues 

through devaluation of bonds could be used to pmmote renewables, thus balancing out the delay in their 

development resulting from the use of an unsafe storage option. 

Structure of long Version 

The long vel'~inn has 226 pages, 60 titbies .md 116 figures. It can he obtained as paper 

\'ersion and electrouically at www.bmu.de. 

Summar), of Theses 

Summary 

Introduction and Background 

I Status Quo and the Aim, of the Study 

2 Terminology 

3 Driving Forces: The Attitudes of Relevant Groups 

to CO?, Capture and Storage 

II Technologies and Process Chains 

4 An Overview of CCS Processes 

5 CO2 Capture Z.I,1ethods tor Power Plant and Hydrogen Production 

6 COl Transport 

7 CO2 Storage 

8 Central Aspects of CO2 Transport Infrastructure 

III Comparative Analysis and Assessment 

9 Criteria for a Comparative Assessment of CCS 

10 Life Cycle Assessment~ for SeI("ctcd CCS-Processes 

II Other Ecological Assessment Criteria for CCS 

12 Development of Electricity and Hydrogen Generation Costs with CCS 

13 Other Energy Sector Criteria 

IV Systems Analysis: A National Perspective 

14 Systems Analysis ofCCS Scenarios 

V Global Aspects 

15 CCS in the International Context 

Appendix 

References 

RECCS Prolect 

25 
26 Table of Contents 

Table of Contents 

Summary of Theses 15 

Summary 21 

Background and Introduction 21 

Driving Forces and the Attitudes of Relevant Groups towards 

Carbon Capture and Storage 21 

CO, Capture Methods 22 

CO, Transport Methods 24 

CO, Storage Methods and Capacity 25 

Criteria fol' a Systematic Assessment of CCS 26 

Comparative Life Cycle Assessments 27 

Other Ecological Assessment Factors for CCS 30 

Economic Comparison of ces and Renewables 30 

The Role of ces inlndllstrialiscd Countries - the Example of the 

German Energy Supply System 32 

Requirements for S1.lccessful International Implementation of CCS 34 

Chapter 1 

Stalus Quo and the Alms of fhe Study 36 

Chapter 2 

Terminology 38 

Chapter 3 

Driving r;orces; 'Ill':: Attitudes of Relevant Groups to CO2 Capture and Storage 39 

3,1 

3.2 

3.3 

3.4 

International and German NGOs 

Industrial Associations and Companies 

German Political Parties 

German Ministries and Expert Committees 

3.4.1 The Federal Ministry of Economics and Technology (BMWi) 

Chapter 4 

An Overview of CCS Processes 

Chapter 5 

5.1 

5.2 

5.3 

5.4 

Capture Methods for Power Plant and Hydrogen Production 

Developments in Power Station Concepts with CO2 Capture 

Concepts for Moving towards Large~Scale Production of Hl 

5.2.1 Large~scale H2 Production Today (Steam Reforming of Natural Gas) 

Learning Curves and Possible Cost Degressions 

Relevant Applications for Energy Systems, Case Study Germany 

Chapter 6 

CO2 Transport -----------------

6.1 Physical State for Transport and Energy Required for Compression 

and Transport 

6,2 

6.3 

Transport Options 

Transport Costs 

41 

42 

42 

43 

43 

45 

50 

50 

58 

58 

59 

60 

61 

63 

65 

68 

Worklnc Group WI, DLR ZSW, PIK 
Table of (ontenll 

Chapter 7 

CO2 Storage 

~-~~ 

7.1 Overview of Methods 

7,2 

7.3 

Relevant Global Storage Options and Their Potential 

Assessment of the Storage Options in Germany as an Example of an 

Industrialised Country 

Chapter 8 

Central Aspects of CO2 Transport Infrastructure 

8.1 

8.2 

8.3 

8.4 

85 

8.6 

Interdependency bet ween Et1crgy U.se and Freight Transport 

Determinants of Additional Freight Transport with CCS 

Technical Aspects of Bulk Transport Capacity 

Networkability of Modes arTransport 

Conclusions 

Case Study: TransporL OptiQn~ for a 700 MW Coal· tired Power Station 

Chapter 9 

Criteria for a Comparative Assessment of CCS 

Chapter 10 

Life Cyde Assessments for Selected CCS~Processes 

10. I Methodology 

10.2 Mathemalical Melhodology Captured versus Avoided CO, 

10.3 Plant and Processes for Conventional Electricity Generation with CCS 

10,4 Plant for Generating Electricity from Renewables 

10,5 Analyses of Individual Electricity Generating Systems 

10.6 Comparison of Energy Generation Systems 

10.7 Sensitivity Analyses of Electricity Generating Systems 

10.8 Conclusions for Electricity Generation 

10.9 Plant and Processes for Conventional Hydrogen Production with CCS 

10.10 Plant for Producing Hydrogen Using Renewables 

10.11 Individual Analyses of Hydrogen Production Systems 

10.12 Comparison of Hydrogen Production Systems 

10.13 Conclusions for Hydrogen Production 

Chapter II 

Other Ecological Assessment Criteria for CCS 

I J.I CO, Capture 

11.2 CO2 Transport 

1 L3 Storing CO, 

I 1·4 A Comparison of Strategies 

Chapter 12 

Development of Electricity and Hydrogen Generation Costs with CCS 

12.1 Future Electricity Generation Costs Taking Account of Technological 

Developments. Fuel Price Rises and Cost of CO2 Emission Certificates 

REUS Pro,le(t 

71 

71 

73 

76 

78 

78 

80 

81 

83 

83 

86 

88 

93 

93 

98 

99 

IUS 

105 

107 

113 

118 

119 

123 

123 

125 

126 

127 

127 

127 

t28 

130 

135 

135 

27 
28 Table of Contents 

12.2 Costs of Hydrogen Production from fossil Resources with CO2 Coapture 148 

12,2,1 Hydrogen Production with CO, Capture 148 

Chapter 13 

Other Energy Secto::r_C::n::' t::e __ r1 __ a_____ _ 

13.1 Social Acceptance 

13,2 Transferability of'Iechnology to Developing Countries 

13.3 Technology Leadership and ExporlOpportunities 

13.4 Import Dependency 

13.5 Security Policy Implications 

13,6 Vulnerability and Comptexity of the System 

13.7 Conflicting Alternative Uses 

Chapter 14 

Systems Analysis of CCS Scenarios 

14,1 CCS in the Energy Economy 

14.2 Scenario Analyses: Assessment of the Strategic Importance of CCS 

14.3 Conclusions of the Scenario Analysis for Germany 

14.4 Applicability of Results to Other CQuntries 

Chapter 15 

CCS in the International Context 

15.1 The Significance of CCS as a Climate Protection Option 

15,2 CCS in a Portfolio afClimate Protection Strategies! Analysis of 

Uncertainty Factors 

15.3 Requirements for an Institutional Framework for CCS 

,---

15.3.1 The Basis for an Institutional Framework: "Cap and Trade" 

Appendix 

Contents 

155 

155 

155 

156 

156 

156 

157 

158 

159 

159 

165 

175 

179 

181 

181 

183 

188 

199 

197 

A.l Physical Properties of CO, 199 

A.2 CO, Capture Methods (to Chapter 5) t99 

A,2,1 Chemical/Physical Absorption 200 

A.2,2 Adsorption on Solids 201 

A,2.3 Cryogenic Distillation 201 

A,2,4 Membrane Method 202 

A,2,5 High-temperature Methods 202 

A.2.6 Conclusions 203 

A.3 Worldwide Overview ofeeS mjeets (to Chapter 7) 203 

A.3.1 Projects within the EU 206 

A.3.2 International Activities and Political Strategies 210 

A,3,3 CCS Projects in Germany 213 

A.4 Central Issues for Planning a CO, Transport Infrastructure (to Chapter 8) 214 

A,S Data Used for Analysing Mass Flows of Fuel and CO, (to Chapter 10) 214 

References 217 

W'orklng Group WI, DlR.lSW. PIK 
This publicatioo is based 00 the Germao research Prolect 

"iikologische Einordnung und strukturell·ijkonomisdlerVerglelch regeneratiyer Energiete<hnologi.n 

mit and.r.n Optlon.n ,um Klim.schutz, .pedell d.r RUckh.ltung und Sp.lch.rung von Kohl.ndloxid 

bei der Nutzung 105lII.r Primarenergl.n" 

00 behalf of the federal Mioistry for the Environment, Nature (onservatioo and Nudear Safety. 

(ontact: 

Federal Ministry for the Environment, 

Natur. (on\erv.llon and Nuclear Safety (BMUI 

Dep. Public Relallon. 

11055 Berlin' Germany 

Telefax: +4930 1830H044 

Homepage: www.bmu.de 

This brochur. is part olthe public relations work olth. 

Federal Ministry for the Environment, Nature Conservation and Nuclear 

Safety. It is distributed f .. e of chal1J' and is not intended for sale. 

Th. brochure is printed on lOa % re<ycled paper. 

Letter ID: 0347  

Commenter: Mary Munn  

Organization: Fond du Lac Reservation  

Letter ID: 0347 Comment ID: 27891 Letter Lines: 47 to 51  

Comment Code: 5000 5. Comments on the Proposed Rule (out of NODA Scope)  

Comment: General The proposed rule is quite specific and seeks to compartmentalize  

comments only to the endangerment that may be caused to underground sources of  

drinking water (USDW). However, the proposal goes on to state that the Class VI  

injection wells are to be one approach "that could be deployed to reduce CO2  

emissions to the atmosphere and help to mitigate climate change."  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  

Letter ID: 0347 Comment ID: 27892 Letter Lines: 52 to 61  

Comment Code: 5700 5.14. Comments on Other Aspects of the Proposed Rule  

Comment:

While such specificity allows for a focused approach, if approved, it may allow  

Class II wells to be used for GS of CO2 under the rule. The use of Class II  

wells for GS of CO2 will likely allow carbon credits in one form or another,  

even though the injected CO2 would be used to enhance the extraction of  

additional fossil fuels (oil or natural gas), which when consumed releases CO2,  

impeding rather than mitigating CO2 emissions.  

If the proposed wells are to be a part of a climate mitigation strategy,  

supporting data must be supplied to verify that goal.  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  
Letter ID: 0347 Comment ID: 27893 Letter Lines: 63 to 129  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: Assessment of the Proposed Rule The proposed rule repeatedly references climate  

change mitigation by the injection of CO2 as the justification for the need for  

the new class of injection well:  

Summary: "EPA is proposing Federal requirements under the Safe Drinking Water  

Act (SDWA) for underground injection of carbon dioxide (CO2) for the purpose of  

geologic sequestration (GS). GS is one of a portfolio of options that could be  

deployed to reduce CO2 emissions to the atmosphere and help to mitigate climate  

change."  

And "If finalized, this proposal would help ensure consistency in permitting  

underground injection of CO2 at GS operations across the U.S. and provide  

requirements to prevent endangerment of USDWs in anticipation of the eventual  

use of GS to reduce CO2 emissions."  

In Part II "What is the EPA Proposing" the proposition reiterates:  

"In addition to protecting USDWs, today's proposed rule provides a regulatory  

framework to promote consistent approaches to permitting GS projects across the  

U.S. and supports the development of a key climate change mitigation  

technology."  

Under Part II A. "Why Is EPA Proposing To Develop New Regulations To Address GS  

of CO2?" Part II. Section 2, states: The Intergovernmental Panel on Climate  

Change (IPCC) has concluded that much of the warming in recent decades is very  

likely the result of human activities (IPCC, 2007). The burning of fossil fuels  

(e.g., from coal fired electric plants and other sources in the electricity and  

industrial sectors) is a major contributor to human induced greenhouse gas  

emissions.  

Fossil fuels are expected to remain the mainstay of energy production well into  

the 21st century, and increased concentrations of CO2 are expected unless energy  

producers reduce the CO2 emissions to the atmosphere. The capture and storage of  

CO2 would enable the continued use of coal in a manner that greatly reduces the  

associated CO2 emissions while other safe and affordable alternative energy  

sources are developed in the coming decades. Given the United States' abundant  

coal resources and reliance on coal for power generation, CCS could be a key  

mitigation technology for achieving domestic emissions reductions"  
And:  

"Congressional climate change legislative proposals (the McCain‐Lieberman bill  

S. 280, the Bingaman‐Specter bill S. 1766, and the Lieberman‐Warner bill S.  

2191) indicate that CCS has the potential to play a significant role in climate  

change mitigation scenarios."  

And:  

"Today's proposal provides a regulatory framework to protect USDWs as this key  

climate mitigation technology is developed and deployed."  

The allusion of mitigating climate change or reducing CO2 emissions by geologic  

sequestration cannot be fairly used as persuasive point for this rule without  

providing data demonstrating the mass balance of energy and carbon dioxide in  

the whole system. A great deal of analysis has been completed and posted on the  

docket of cost and incremental cost within the proposed rule for CCS and GS  

implementation but no analysis is made in terms of the actual amount carbon  

dioxide that will be sequestered in relation to the amount of carbon dioxide  

emitted throughout the process (Cost: EPA‐HQ‐OW‐2008‐0390‐0073 and EPA‐HQ‐  

OW‐2008‐0390‐0094).  

A mass balance of the participating fossil energy processes, generating the CO2,  

must be evaluated to determine if any real reduction in CO2 can be made. CO2 is  

emitted during the excavation and transport of the fossil fuel to a power plant.  

Additional power will be required, and will emit additional CO2, to provide the  

energy to extract the CO2 from the emission stream, to compress, transport, and  

to inject the CO2 into a geologic formation.  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  

Letter ID: 0347 Comment ID: 27894 Letter Lines: 131 to 157  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: Very little data is available to evaluate the energy balance of various carbon  

capture processes. The evaluations available limit the efficiency of carbon  
capture (CC) to a percent recovered from the feed stack to the emission stack.  

Capturing the carbon is very energy intensive and may increase energy demand by  

up to 50%. (www.lowtechmagazine.com accessed October 27 2008).  

According to Greenpeace International: False Hope: Why carbon capture and  

storage won't save the climate, "capturing and storing carbon uses lots of  

energy; anywhere from 10‐40% of a power station's capacity. An energy penalty of  

just 20% would require the construction of an extra power station for every four  

built. These reductions in efficiency will require more coal to be mined,  

transported, and burned, for a power station to produce the same amount of  

energy as it did without CCS."  

The attached summary of a study by Wuppertal Institute, the German Aerospace  

Center (DLR), Zentrum fur Sonnenenergie‐ und Wasserstoff‐Forschung Baden‐  

Wurttemberg (ZSW) and the Potsdam Institute for Climate Impact Research (PIK)  

for the German government (the full report available at: www.wupperinst.org,  

accessed on line Dec. 23 2008) offers an in depth study of CCS that evaluates  

the various power plant designs, transport, and storage costs; accesses life  

cycle, ecological criteria, carbon neutrality etc. Estimates in the study show a  

20 to 40% increase in energy consumption and the process will only lower  

emissions of CO2, ignoring the increases of other greenhouse gases (GHG). [SEE P. 6 OF  

EPA‐OW‐2008‐0390‐0347.PDF FOR THIS DOCUMENT.]  

Consuming an additional 20 to 50% more coal to energize the capture of CO2 is a  

questionable tactic that must supported by transparent data analysis.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  

Letter ID: 0347 Comment ID: 27895 Letter Lines: 159 to 179  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: Even as this proposed rule is being considered, the EPA is soliciting  

"applications to conduct research to support the development of sound risk  

management strategies for the underground injection of anthropogenic carbon  

dioxide (CO2)" (accessed online October 6 2008  

http://es.epa.gov/ncer/rfa/2008/2008_star_gsc02.html). The technology for GS of  

CO2 is not yet available or known to be safe.  
Social Justice: The United Nations Environmental Progamme states: "Globally  

around $300 billion or 0.7 per cent of global GDP is being spent on energy  

subsidies annually. The lion's share is being used to artificially lower or  

reduce the real price of fuels like oil, coal and gas or electricity generated  

from such fossil fuels. Cancelling these subsidies might reduce greenhouse gas  

emissions by as much as six per cent a year while contributing 0.1 per cent to  

global GDP."  

Mr. Steiner added: "Whereas fossil fuel subsidies are an example of a blunt  

policy instrument, perpetuating old and inefficient economic models, the CDM is  

an example of a more intelligent, market‐based mechanism that is fostering the  

transition to a modern Green Economy". (Accessed online Nov. 14, 2008  

http://www.unep.org/Documents.Multilingual/Default.asp?DocumentID=543&ArticleID=  

5902 )  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  

Letter ID: 0347 Comment ID: 27896 Letter Lines: 181 to 187  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: Recommendations:  

∙ A thorough mass balance of the CO2 generated in the participating fossil  

energy processes, generating CO2 must be demonstrated to prove the feasibility  

of the proposal; including mining and transport of the fossil fuel to power  

plants, extraction and compression of the CO2 emissions, transport, and  

injection the CO2 into a geologic formation.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  

Letter ID: 0347 Comment ID: 27897 Letter Lines: 189 to 192  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: ∙ If carbon credits are developed, they must not apply to other UIC wells except  

specific Class V experimental wells. To use sequestered carbon dioxide under the  
auspices of this rule, to enhance the recovery of additional fossil fuels is  

imprudent and illogical.  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  

Letter ID: 0347 Comment ID: 27898 Letter Lines: 194 to 201  

Comment Code: 5200 5.4. Comments on the Proposed Financial Responsibility Requirements (146.85)  

Comment: ∙ Liability issues must be clarified in regard to human welfare and  

environmental protection rather than ensuring the financial viability of the  

commercial entities of power plants, pipeline, and well operators. Proponents  

wish to diminish liability for CCS and GS activities (EPA‐HQ‐  

OW‐2008‐0390‐0150.1) and EPA must explicitly recognize the threat of an  

uncontrolled release of CO2 to human life. Acknowledgement of the potential  

hazard, in a manner similar to OSHA guidelines on "gases, vapors, fumes, dusts,  

and mists ‐ 1926.55" would be beneficial.  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  

Letter ID: 0347 Comment ID: 27899 Letter Lines: 203 to 207  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: ∙ Fond du Lac will defer to the experts in the case of pipeline and well  

integrity and the long term safety of geologic sequestration of carbon dioxide.  

However, the skill of deep drilling brings to mind the mudflow disaster of  

Sidoarjo Porong, East‐Java Indonesia, which began in May 2006 and is still  

flowing to this day.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  
Letter ID: 0347 Comment ID: 27900 Letter Lines: 209 to 211  

Comment Code: 5200 5.4. Comments on the Proposed Financial Responsibility Requirements (146.85)  

Comment: ∙ Financial Assurance should be required for any unforeseen effects of a given  

project.  

Individual Response: This comment pertains to EPA’s proposed GS rule (73 FR 43492) and is outside the

scope of the Notice of Data Availability. Please see responses to comments on the proposed rule for

EPA’s response to similar comments.  

Letter ID: 0347 Comment ID: 27901 Letter Lines: 214 to 225  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: Although the effort made to address the serious issues of climate mitigation  

through CCS is greatly appreciated, the effort largely appears to mitigate CO2  

emissions via a complex system that will, in reality, increase fossil energy  

consumption. With projected consumption to increase more than 30% by 2030 and  

CCS adding at least 20% additional demand, one may wonder if this proposal  

equates to yet another subsidy for fossil fuel industry.  

The absence of analysis of the carbon neutrality of this project is a serious  

omission. An analysis of this kind should have been the first step in evaluating  

this proposal, yet it is not addressed in the rule or in any of the supporting  

documentation. An endeavor of this magnitude should be demonstrably carbon  

neutral and hopefully operate as a true carbon sink.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  

Letter ID: 0347 Comment ID: 27902 Letter Lines: 227 to 230  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: The commitment of resources; human, material, and capital, required to construct  

the network of pipelines and wells for a project that is most likely  

energetically untenable, cannot be supported without a proper evaluation of  
carbon throughput of the entire process.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.  

Letter ID: 0347 Comment ID: 27903 Letter Lines: 232 to 256  

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA  

Comment: This rule is written for the existing energy production system. The reliance on  

fossil energy must change to meet the challenge of climate change. Barriers to  

the success of alternate sources of energy must be removed so the issue can be  

faced head on. This rule will impede and obstruct progress for those competing  

industries.  

The resources required to pursue this undertaking will be in direct competition  

with efforts focused on sustainable energy sources and alternative, arguably  

more effective carbon sequestration, utilizing wetland restoration, improved  

agricultural methods, and sustainable forestry practices that have numerous and  

vital fringe benefits.  

Experts in carbon sequestration know that utilizing biologic methods of carbon  

capture is cost effective and will include economic benefits. For example,  

wetland protection and restoration will not only sequester carbon but will  

purify water, impede drainage (flooding), and replenish aquifers. Many avenues  

could be used to reverse engineer the activities that drained these wetlands.  

Many studies including the Kyoto Protocol Wetland Restoration and Management and  

the Wilderness Society Forest Carbon Report support these alternative carbon  

sequestration mechanisms.  

Reduction of carbon emissions to the atmosphere is the primary driver for this  

new class of well, proof that carbon capture and sequestration will provide a  

net removal of CO2 must be provided else any reference to the reduction of CO2  

emissions or climate mitigation must be removed from the document.  

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.